Who Needs Hazardous Waste Training?

Facilities that manage hazardous waste must comply with the Resource Conservation and Recovery Act (RCRA) regulations. Under RCRA, employers are required to train personnel on proper hazardous waste management and comply with stringent requirements for generating, storing, treating, and disposing of hazardous waste. 

When and how often EPA requires hazardous waste training depends on monthly hazardous waste volume ("generator status") and other factors. For help choosing RCRA training, read the FAQ below or watch the Who Needs Hazardous Waste Training Video.

 

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Who must complete RCRA hazardous waste training?
The US EPA RCRA hazardous waste training requirements that apply to you and your staff will depend on how much hazardous waste your site generates in one calendar month. 

Large Quantity Generators (LQG)
  • Generate ≥ 1,000 kilograms (2,200 pounds) of regular hazardous waste; or
  • Generate > 1 kilogram (2.2 pounds) acutely hazardous waste.
  • Must follow the RCRA 90-day accumulation rules.
LQGs have the most stringent training requirement. RCRA requires that LQGs train "personnel" annually. US EPA defines "personnel" at 40 CFR 260.10 as "all persons that work at, or oversee the operations of, a hazardous waste facility, and whose actions or failure to act may result in noncompliance with the requirements." This means anyone who could mismanage your hazardous waste by doing the wrong thing needs to be trained annually. [40 CFR 262.34(a) and 265.16] See hazardous waste training options for managers and personnel at LQG facilities. 

 Small Quantity Generators (SQG)
  • Generate < 1,000 kilograms (2,200 pounds) of regular hazardous waste; and
  • Generate ≤ 1 kilogram (2.2 pounds) of acutely hazardous waste.
  • Must follow the RCRA 180-day accumulation rules, but may choose to follow the 90-day rules for LQGs.
SQGs have a less stringent training requirement. The regulations state that small quantity generators of RCRA hazardous waste must ensure that all employees are “thoroughly familiar” with waste handling and emergency procedures relevant to their job responsibilities. See hazardous waste training options for personnel at SQG facilities. 

Very Small Quantity Generators (VSQG)​
  • Generate ≤ 100 kilograms (220 pounds) of regular hazardous waste.
  • Not subject to the 90- or 180-day accumulation rules, but may choose to follow either one.
VSQGs (formerly known as Conditionally Exempt Small Quantity Generators (CESQGs)) are not subject to any explicit RCRA training requirements. For VSQGs, generators must use best management practices to train their employees as often, and as long, as appropriate to ensure there are no non-compliance issues. See hazardous waste training options for VSQG hazardous waste personnel. 
What training is required?
LQGs following the 90-day rules must ensure that their facility personnel successfully complete "a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance." [40 CFR 265.16(a)(1)]

SQGs following the 180-day rules must ensure that all employees are thoroughly familiar with waste handling and emergency procedures relevant to their job responsibilities. This means training them to manage hazardous waste in a manner that keeps the facility in compliance with the RCRA rules, and teaching them how to respond in the event of a release, fire, or explosion of the hazardous waste. [40 CFR 262.34(d)(5)(iii)]

VSQGs (formerly CESQGs) do not have any explicit training requirements. Although VSQGs are exempt from the majority of the RCRA rules, VSQGs are required by the regulations to perform waste identification in order to prove their generators status. They are also required to ensure that hazardous waste is disposed of in the proper manner. Therefore, although training may not be explicitly required, it is good management practice to ensure employees know what rules apply to the site. [40 CFR 261.5]
Is hazardous waste training only for emergency responders?

No. This is a common misconception. The EPA’s requirements emphasize the inclusion of training on the facility’s hazardous waste contingency plan for LQGs and on specific emergency response procedures for LQGs and SQGs. These details are in addition to the general performance standards.

See HAZWOPER training for emergency responders.

How much training is required?
Unlike OSHA, the EPA does not specify a particular duration of training for any of the different generator types. Someone who oversees the entire hazardous waste program may require more training than someone who simply performs weekly inspections. The employer must decide what is adequate to ensure RCRA compliance.
What penalties might I face if I don’t have current or correct training?
RCRA penalties for all generators depend on the type of violation. The EPA can impose civil or criminal penalties upon a site based on intent. A civil penalty can be for simple mistakes, like a generator not providing training to all employees. But even for mistakes, a RCRA civil penalty can be as high as $70,117 per day and per incident.

Criminal penalties are imposed if the EPA can prove that a generator purposely acted against the rules. For instance, if a generator was cited for not training personnel and failed to provide training after the citation, then there is evidence that the generator knew training was needed but consciously chose not to provide it. In this case, the EPA can impose a criminal penalty up to and including a jail sentence of two to five years.
If I am trained by Lion Technology Inc., may I train others at my facility?
Lion’s training products and services are designed to give comprehensive knowledge about the regulatory requirements for managing hazardous waste. You will learn what you need to teach your personnel about the RCRA regulations. You and your company’s management will have to decide whether or not you have the depth of knowledge needed to train personnel for the activities at your facility. Remember that LQGs must specifically train their employees in on-site management of site-specific waste handling.
What is a “generator status”?
Based on the amount of hazardous waste your site generates, you will fall into one of three categories: Large Quantity Generator (LQG), Small Quantity Generator (SQG), and Very Small Quantity Generator (VSQG); this is your generator status under the RCRA regulations. Your generator status then dictates which hazardous waste accumulation rules you may or may not follow. The regulatory limits are per calendar month, as follows:

    LQG - Generators who must follow the 90-day accumulation rules
  • Generates ≥ 1,000 kilograms (2,200 pounds) of regular hazardous waste
  • Generates > 1 kilogram (2.2 pounds) acutely hazardous waste
    SQG - Generators who must follow the 180-day accumulation rules but may choose to follow the 90-day accumulation rules
  • Generates < 1,000 kilograms (2,200 pounds) of regular hazardous waste
  • Generates ≤ 1 kilogram (2.2 pounds) of acutely hazardous waste
    VSQG - Generators who are not subject to the 90- or 180-day accumulation rules but may choose to follow either one
  • Generates ≤ 100 kilograms (220 pounds) of regular hazardous waste
  • Generates < 1 kilogram (2.2 pounds) of acutely hazardous waste
When, and how often, must I train my personnel?
LQGs must ensure that their employees successfully complete training within six months of becoming RCRA personnel and then repeat the training annually thereafter. [40 CFR 262.34(a)(4) and 265.16(b) and (c)]

SQGs following the 180-day rules have no explicit time frame for how often or how long the training must be. Generators must use best management practices to train their employees as often, and as long, as appropriate to ensure there are no non-compliance issues. [40 CFR 262.34(d)(5)(iii)]

VSQGS do not have any explicit training requirements. Generators must use best management practices to train their employees as often, and as long, as appropriate to ensure there are no non-compliance issues.
What must be covered in RCRA training?
LQGs have very specific criteria to meet in order to satisfy RCRA training requirements. At a minimum, the training must be designed to ensure that personnel are able to respond effectively to site-specific emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including, where applicable:
  • Inspecting, repairing, and replacing emergency and monitoring equipment
  • Key parameters for waste feed cut-off systems
  • Communication and alarm systems
  • Response to fires and explosions
  • Response to groundwater contamination
  • Shutdown of operations
SQGs have no explicit criteria for training other than making sure employees are thoroughly familiar with waste handling and emergency procedures for the site. Best management practices should be utilized to ensure employees are trained to avoid compliance issues.

VSGQs do not have any explicit training requirements. Although VSQGs are exempt from the majority of the RCRA rules, VSGQs are required by the regulations to perform waste identification in order to prove their generators status. They are also required to ensure that hazardous waste is disposed of in the proper manner. Therefore, although training may not be explicitly required, it is good management practice to ensure employees know what rules apply to the site. [40 CFR 261.5]
Do my employees have to receive classroom training?
LQGs are given the choice of “a program of classroom instruction or on-the-job training" that teaches them to perform their duties in a way that ensures the facility’s compliance.” [40 CFR 265.16(a)(1)]

SQGs and VSQGs have no explicit regulatory language regarding classroom training. A best management practice may be to send only one, some, or all employees to training so that they can stay abreast of any regulatory changes and communicate that back to the site.
Who can provide training?
The program must be directed by a person trained in hazardous waste management procedures. There are no specific requirements for qualification of trainers. The EPA does not "approve," "certify," or otherwise accredit trainers or training programs under RCRA.
Is online training an acceptable form of training by the EPA?
Yes. The EPA does not specify requirements for the method of delivery for the training. You may use public workshops, a classroom setting at your facility, self-directed online programs, live webinars, or on-the-job training programs to provide your employees with the training they need.
If my employees received emergency response training under OSHA, must I repeat this training for RCRA?
If you have trained your employees under the OSHA standards at 29 CFR 1910.120(p)(8) and 1910.120(q) and you’ve met the overall facility training requirements under RCRA, then no, the facility is not required to provide separate emergency response training. You must include proof of this OSHA training in your RCRA training records.
Does completion of RCRA hazardous waste training qualify me to sign a Uniform Hazardous Waste Manifest?
No. By signing a manifest you are certifying compliance with transportation regulations. Comprehensive training in the Department of Transportation’s (DOT) hazardous materials regulations is required.
Do I need to train contractors doing work at my site?
LQGs are required to provide and document training for all personnel; this would include contractors. If you rely on a contractor to assist in on-site management of hazardous waste or hire a contractor who produces hazardous waste on your site (e.g., painting or maintenance crews), then their training must be part of your written training plan.

The rules do allow new personnel to work under the direct supervision of a trained person for up to six months. If you have occasional one-time contractors for less than six months, you may satisfy their training requirements by assuring they are supervised in all waste management-related aspects of their job.
Do I need to be able to prove I was trained or that I trained my employees?
LQGs are required to keep specific training records for all “personnel.” This includes documenting the training with the following information:
  • Employee's name
  • Employee's job title
  • Employee's job description
  • Written description of the amount and type of training the employee received
  • A record or document that proves the training has been given to and completed by the employee
SQGs have no explicit requirement to document training. However, upon inspection, an inspector could ask you to prove that employees have been trained. Without training documentation of some kind, this proof might be hard to provide. Good management dictates some sort of record of training be kept for small quantity generators. An example could be a sign-in sheet documenting the names of employees who attended, along with a description of the training and the date.
Will training with Lion help me maintain my professional certifications?
Lion offers Continuing Education Units (CEUs), calculated based on training hours, which can be submitted for approval to help you maintain certification from organizations including: AHMP, ABIH, IHMM, NEHA, REHS, CCMP, and others.

While these groups typically do not pre-approve training programs that offer certification points, professionals can submit Lion CEUs for approval from their certifying organization.