RCRA Training Requirements for SQGs

If a small quantity generator (SQG) site does not comply with all regulations found in 40 CFR 262.16, it may be subject to more stringent regulations for large quantity generators or the regulations for permitted treatment, storage, and disposal facilities, which are even more stringent.

This article clarifies how the above-mentioned regulations translate to training requirements and recommendations for hazardous waste personnel at SQG sites.

If your site is an SQG, this article will help you understand Federal RCRA training requirements for your site. If you are not sure of your site’s generator status, start here: How to Determine RCRA Generator Status.

SQG Personnel Must Be “Thoroughly Familiar”

One of the regulations that generators must follow under the SQG exemption is 40 CFR 262.16(b)(9)(iii). This regulation requires that SQGs “must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies.”

Although there is no explicit requirement for scheduling training for SQG personnel, we recommend that anyone who can cause noncompliance with the SQG exemption is trained before being placed in that position.

Training should be reviewed by the generator on a periodic basis. Update and refresher training should be provided annually, whenever an employee’s performance shows a need, and whenever regulatory or operational changes make it necessary.

How Do You Prove Familiarity?

Imagine this situation: An inspector from the US EPA shows up at your facility. You believe you have followed the regulations to a tee, but there is a simple rule that you violated. Whether by mistake or ignorance, the inspector may interpret this violation to mean that someone at your site is not thoroughly familiar with the regulations because thorough familiarity would have prevented the error.

A record of your personnel’s hazardous waste training is much stronger evidence of familiarity than your word. Proper recordkeeping and a good-faith effort to correct the violation on the spot could be the difference between zero citations and two citations—one for the error and one for lacking thorough familiarity.

Stricter State-specific Regulations for SQGs

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.

Examples of Stricter State Regulation

Kansas has four generator categories: conditionally exempt small quantity generator (CESQG), Kansas small quantity generator (KSQG), small quantity generator (SQG), and large quantity generator (LQG). Kansas explicitly requires annual training for SQG and KSQG personnel [K.A.R. 28-31-262a(d)(1) and 28-31-262a(e)(4)].

In Maryland, there is no equivalent to the Federal SQG. If your site is a small quantity generator under the Federal rules, it is a fully regulated generator (FRG) under Maryland’s regulations. However, fully regulated generators (FRGs), like SQGs, can accumulate waste for up to 180 days if they meet certain requirements [COMAR 26.13.01.03B(28-1) and 26.13.03.03-4C(3)].

Tags: hazardous waste management, RCRA, RCRA Training