RCRA Training Requirements for VSQGs

While there is no explicit training requirement for very small quantity generator (VSQG) personnel, employees must know enough to remain in compliance with applicable hazardous waste regulations so as to avoid penalties and unwanted hazardous situations.

If a VSQG site does not comply with all regulations found in 40 CFR 262.14, it may be subject to more stringent regulations, such as the regulations for small or large quantity generators or the regulations for permitted treatment, storage, and disposal facilities, which are even more stringent.

Training requirements for small quantity generators and large quantity generators differ. If you are not sure of your site’s generator status, start here: How to Determine RCRA Generator Status.

Training Recommendations for VSQGs

For VSQGs, we strongly recommend RCRA training to ensure your facility can achieve and maintain compliance. VSQGs need to know:

• Conditions for exemption for VSQGs [40 CFR 262.14].
• Hazardous waste determination and recordkeeping [40 CFR 262.11(a)–(d)].
• Generator category determination [40 CFR 262.13].

Stricter State-specific Regulations for VSQGs

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

In California, the term “very small quantity generator” is defined in the regulations but is not a recognized generator category. VSQG sites in California follow California’s rules for small quantity generators (SQGs) at 22 CCR 66262.16.

In New Hampshire, if a VSQG wants to accumulate more than 200 kg of non-acute hazardous waste for longer than 90 days, its employees need to be “thoroughly familiar” with proper waste handling/emergency procedures [N.H. Admin. Rules, Env-HW 508.03(i)]. How do you prove familiarity?

RCRA Training for Very Small Quantity Generators

This RCRA training covers the keys to compliance with the EPA’s hazardous waste management standards for VSQGs. Managers and personnel who complete this course develop skills to navigate and apply hazardous waste, universal waste, and used oil regulations at a VSQG facility.

Tags: hazardous waste management, RCRA, RCRA Training