RCRA Training Requirements for LQGs

For large quantity generators (LQGs) of hazardous waste to avoid more stringent regulations for permitted hazardous waste facilities, they must comply with all provisions under 40 CFR 262.17. That includes 262.16(7)(a)(7), the regulation that describes LQG training requirements.

This article clarifies who must be trained at an LQG site, what and how much training is needed, and when and how often that training is required.

If your site is a large quantity generator, read on. If you are not sure of your generator status, start here: How to Determine RCRA Generator Status.

Who Must Be Trained at an LQG Site

Resource Conservation and Recovery Act (RCRA) training is required for all hazardous waste personnel at large quantity generator sites. That means anyone at the facility whose job could affect hazardous waste compliance, whether they are doing the work or overseeing those who are. The definition of personnel is intentionally broad and covers more than just employees who physically handle waste; it extends to anyone whose actions, or failure to act, could result in a compliance violation under RCRA.

What and How Much Training Is Required for LQGs

Hazardous waste personnel must successfully complete a training program that teaches them to perform their duties in a way that ensures the facility’s compliance. This can be online, in the classroom, or on the job.

At a minimum, training “must be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems” [262.17(a)(7)(i)(C)].

The EPA does not specify a duration for hazardous waste training, unlike some other Federal agencies. The duration of RCRA training should be commensurate with the employee’s job responsibilities and be sufficient to meet the requirements of 40 CFR 262.17(a)(7) described above. It is the employer’s responsibility to ensure training is adequate to maintain compliance with the RCRA hazardous waste regulations.

When and How Often Training Is Required for LQGs

Facility personnel at large quantity generator facilities must complete RCRA training annually. Lion recommends that personnel complete annual RCRA refresher training on a date as close to the training anniversary date as practicable, based on the previous year’s training.

Untrained employees must work under direct supervision of a trained employee until training is done. Employers must provide adequate RCRA hazardous waste training to personnel within six months of the latest of three dates: date of hire, date of assignment to the facility, or date of assignment to a new position at the facility.

Stricter State-specific Regulations for LQGs

State hazardous waste programs are required to be at least as stringent as the Federal RCRA regulations. Lion Membership (included with all Lion EH&S courses) provides access to Lion’s up-to-date summaries of each state’s hazardous waste regulations.

An Example of Stricter State Regulation

In New Hampshire, annual training near the training anniversary is not just best practice; it is the rule. Annual training must occur “no more than 90 days prior to and no more than 90 days after the anniversary date of the initial training” [N.H. Admin. Rules, Env-HW 509.02(h)].