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Hazardous Waste Training Requirements

May 11, 2021

The ever-popular Resource Conservation and Recovery Act (RCRA) mandates that all personnel involved in hazardous waste management have job-specific training. This blog will speak (1) to Management Education, and then categorically to employee training requirements for (2) Generation; (3) Transport; and (4) Treatment, Storage, and Disposal.

  1. Management
  2. Generation 
  3. Transport
  4. Treatment/Storage/Disposal
  1. Hazardous waste disposal training requirements for management

The academic requirements to become a hazardous waste manager vary across employers. However, in virtually all cases the minimum educational prerequisite is—or should be—an undergraduate degree. This is typically in chemistry or biochemistry, environmental science or engineering, waste management, or toxicology. 

But if you have someone onboard with a B.S. in Adventure Education who demonstrates a flair for hazardous material removal—that’s okay, so long as he or she has job-specific training about handling & removing chemical, biohazard, and/or radioactive wastes without defoliating the entire neighborhood or otherwise creating your very own backyard Chernobyl

But wait…there’s more…

Depending on what kind of hazardous material removal you need to get done, you or your hazmat manager might need additional coursework, such as OSHA workplace hazards management training (WHMT), instruction about workplace emergencies involving hydrogen sulfide gas (H2S Alive), and/or training about the transportation of dangerous goods (TDG).

Also, it’s not unusual for larger private and public entities to require a graduate degree of those who aspire to hazardous waste management leadership.

All that said, given the high legal, financial, and ethical stakes involved in hazardous material disposal, you should get expert advice to make sure your chemical disposal leadership is up-to-snuff, educationally speaking. You can get expert advice about this here.

  1. Hazardous waste disposal training requirements for hazmat generators

EPA personnel-training requirements differ according to what size “generator” the agency considers you. In general, you’re a…

  • Large Quantity Generator (LQG) if you generate 1,000 kilograms per month or more of hazardous waste, or more than one kilogram per month of acutely hazardous waste  
  • A Small Quantity Generator (SQG) if you generate more than 100 kilograms, but less than 1,000 kilograms of hazardous waste per month 
  • Or a Very Small Quantity Generator (VSQG) if you generate 1000 kilograms or less per month of acutely hazardous waste

Large Quantity Generators. If you’re considered an LGQ by the EPA, specialized training is required for all your hazardous waste personnel within six months of bringing them onboard. The EPA defines “hazardous waste personnel” as anyone on your staff whose actions—or inactions—might result in noncompliance with applicable RCRA regulations. 

Put another way: it’s anybody and everybody involved in selecting, marking, labeling, inspecting, moving, or otherwise handling your hazardous waste containers.

Also note: all staff must be adequately trained who deal with your hazardous waste, either daily or incidentally—not just your emergency responders, but also personnel whom you might not consider at first blush. 

E.g., if your accountant occasionally rolls up her sleeves to help move around a few barrels of oozing gook, she still might be considered “hazardous waste personnel” if she’s somehow involved in “reading and applying” federal and/or state hazardous waste regulations.

Also bear in mind that such training is required of any outside contractors who might assist you with onsite hazardous waste management—or who might incidentally produce hazardous waste on your site (such as painters, repair companies, or renovators). In this regard, it’s imperative that you get expert advice.

Small and very-small generators. VSQG and SQG hazardous waste personnel need only be  “thoroughly familiar” with proper waste handling and emergency response procedures, per the EPA.

Although there’s no specific requirement for VSQGs or SQGs to have documented proof of individual training, common sense dictates the need for it. An inspector could ask for proof, and not being able to present it on demand is going to invite closer-than-usual scrutiny. 

Minimally you should document dates and provide descriptions of hazmat training sessions for your VSQG and SQG personnel. Also, have sign-in sheets to record which of your employees have attended them.

  1. Hazardous waste disposal training requirements for transporters

As if life weren’t complicated enough, federal training requirements for hazmat waste transporters are regulated simultaneously by three different agencies: the EPA, OSHA, and the DOT.  And there are also requirements enforced by the Federal Motor Carrier Association (FMSCA) and the Transportation Safety Administration (TSA). By way of review:

  • The EPA is an independent agency of the federal government. It is charged with consolidating federal research, monitoring, standard-setting, and enforcement activities into one agency.
  • OSHA concerns itself with health & safety standards for both private- and public-sector employees.   
  • The federal DOT oversees all facets of transportation: cars, trains, trucks, planes, boats.
  • The FMSCA administers rules that stipulate how hazardous material is properly classed, described, packaged, marked, and labeled for transit.
  • The TSA conducts background checks as part of the hazmat-hauler application process, which takes up to 60 days to complete.

Given that regulations for hazardous waste transport effectively emanate from five different agencies, it’s virtually impossible to provide a list of rules that might remain relatively static over time. Also, in that required training is both “initial and recurrent,” it must be updated periodically—usually annually. (Did we mention it might be a good idea to get expert advice?

With those caveats, here’s a partial list of training that your hazardous-waste transport employees must receive, as there might be more depending on individual job duties.  Among them:

  • Security awareness training about the security risks associated with hazmat transportation, and specific methods designed to diminish them
  • Function-specific training relative to the particular knowledge and skills required for an individual  to perform assigned hazmat-transport responsibilities properly and safely
  • Safety training for drivers, warehouse workers, and any other employees who handle any hazardous waste in advance, during, and/or subsequent to its transportation
  • Specialized driver training pertaining to vehicle inspection and operation; vehicle handling in diverse conditions; and special rules pertaining to tunnels, bridges, and railroads (see FMSCA)
  • Advanced security training for companies required to have a security plan relative to their hazardous waste management
  • Hazardous Waste Operations and Emergency Response (HAZWOPER) certification for employees who must drive onto hazardous waste sites, enter EPA-regulated treatment/storage/disposal facilities, or respond to hazardous waste emergencies 
  1. Hazardous waste training requirements for treatment/storage/disposal facilities

The RCRA requires that your facility personnel be certified to “perform their duties in a way that ensures the facility’s compliance” with hazardous waste regulations. Yearly recertification is required, and includes but is not limited to:

  • In general: refresher coursework including updates on differentiating solid waste from hazardous waste; understanding waste codes, disposal options, and land ban requirements; determining your  generator status; satellite accumulation vs. permanent storage; container requirements; facility standards, recordkeeping mandates; etc.
  • About differentiating among wastes: a review of characteristics for universal wastes, waste oils, electronic waste, and metal waste; as well as addressing various updated requirements for their respective treatments and disposal. 
  • As to legal requirements: Updates to liability and due diligence concerns; RCRA enforcement trends, latest RCRA preferences for organization and management of compliance data; etc.

As you might guess, different states have different requirements for ongoing certification. For example, in California the requirement is 24 contact hours of continuing education every two years. As in many states, these courses must be approved by REHS Continuing Education Accreditation Agencies.  

The upshot

As they tend to come from more than one government bureaucracy at haphazard intervals, environmental regulations are plentiful, evolving, and challenging to track. Ignoring or misunderstanding them can subject you to pecuniary and even criminal consequences.  RCRA civil penalties can be as high as $76,764 per day, and poor employee training is one of the most frequently cited violations.

In sum, it’s crucial to get expert advice. And thank you for reading our blog!

Disposal of hazardous waste doesn’t have to be painful.