Who Needs Hazardous Waste Training?
Facilities that manage hazardous waste must comply with the Resource Conservation and Recovery Act (RCRA) regulations. RCRA requires employers to train personnel 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.
Find hazardous waste training
US EPA defines “hazardous waste personnel” as all persons who 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 (of the RCRA regulations)."
Personnel must complete annual hazardous waste refresher or “RCRA refresher” training and may not work unsupervised until training is complete.
Common job responsibilities for hazardous waste personnel include:
- Identify or count hazardous waste
- Choose hazardous waste containers
- Mark or label containers
- Handle or move waste or waste containers
- Inspect containers
- Operate a waste-generating process
- Manage waste in satellite areas
- Read and apply Federal or state hazardous waste regulations
RCRA training is required for personnel who work at large and small quantity generator facilities. For very small quantity generators, we strongly recommend RCRA training to ensure your facility can achieve and maintain compliance.
Small Quantity Generators (SQG)
An SQG is a facility that generates less than 1000 kg (2,200 pounds) of hazardous waste and 1 kg or less of acutely hazardous waste per month.
All hazardous waste personnel at SQG facilities must be trained to be “thoroughly familiar” with proper waste handling and emergency response procedures relevant to his or her job. Training should be repeated or supplemented when the employee’s job responsibilities change or the facility’s operations change.
Very Small Quantity Generators
Formerly called “Conditionally Exempt Small Quantity Generators,” a Very Small Quantity Generator (VSQG) is a facility that generates 100 kg or less of hazardous waste per month. While there is no explicit training requirement for VSQG personnel, employees should know enough to keep your hazardous waste in compliance with Federal and State regulations.
RCRA Training for VSQG personnel.
For small quantity generators (SQGs), US EPA requires that all hazardous waste personnel are "thoroughly familiar" with the RCRA regulations. To ensure personnel fully understand their responsibilities and have up-to-date training, annual training for SQG personnel is a best practice.
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”
See 40 CFR 262.17(a)(7)
A manager who oversees your facility's entire hazardous waste program likely needs more training than a general laborer, for example. Ultimately, it is the employer’s responsibility to ensure training is adequate to maintain compliance with the RCRA hazardous waste regulations.
Lion's RCRA hazardous waste management training options include:
RCRA Hazardous Waste Management Workshop (2 days)
RCRA Hazardous Waste Management Online Course (14 hours)
RCRA Hazardous Waste Refresher Online Course (8 hours)
For general site personnel like operators and laborers, we recommend:
Storing Hazardous Waste–Ops Online Course (2.5 hours)
Lion hazardous waste workshops, online courses, and webinars are designed and delivered by experienced hazardous waste instructors, experts, and research staff. RCRA courses are updated throughout the year to keep training content fresh and up to date with the latest Federal RCRA and State hazardous waste regulations.
Per 40 CFR 262.17(a)(7), RCRA training can be completed via “a program of classroom instruction, online training (e.g., computer based or electronic), or on-the-job training" that teaches personnel to perform their duties in a way that ensures the facility’s compliance.”
Browse online RCRA training options or in-person RCRA workshops
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.
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.
In addition to monetary penalties, failure to train hazardous waste personnel can lead to serious injury and emergency releases. Waste that is not properly managed and disposed of opens the door to future liability under programs like the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
Comprehensive training in the Department of Transportation’s (DOT) 49 CFR hazardous materials regulations is required. See the Hazmat Ground Shipper Certification workshop or online course.
Large Quantity Generator (LQG)
Small Quantity Generator (SQG)
Very Small Quantity Generator (VSQG),
This is your generator status under the RCRA regulations, which dictates the specific requirements within 40 CFR with which you must comply.
The waste accumulation 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
- Generates < 1,000 kilograms (2,200 pounds) of regular hazardous waste
- Generates ≤ 1 kilogram (2.2 pounds) of acutely hazardous waste
- Generates ≤ 100 kilograms (220 pounds) of regular hazardous waste
- Generates < 1 kilogram (2.2 pounds) of acutely hazardous waste
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.
- 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
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.