Training Requirements for Hazardous Waste Generators According to Size
December 18, 2024
This blog entry describes the hazardous waste generator training requirements for generators according to their size and the type of waste they handle. Q&As include:
- Who is considered a Large Quantity Generator of hazardous waste?
- What are the training requirements for Large Quantity Generators?
- How should LQGs document their training efforts?
- Who is considered a Small Quantity Generator of hazardous waste?
- Who is considered a Very Small Quantity Generator of hazardous waste?
- What are the training requirements for Small Quantity Generators?
- What are the training requirements for Very Small Quantity Generators?
- What exactly does hazmat training for LQGs involve?
- Are there state-specific rules for hazmat training?
- Who can provide the required training for hazardous waste management?
- Where can you get expert help with employee hazmat training?
1. Who is considered a Large Quantity Generator of hazardous waste?
The EPA categorizes you as a Large Quantity Generator (LQG) if you generate 2,200 lbs. (1,000 kg.) or more of hazardous waste per month, or more than 2.20 lbs. (1.0 kg.) of acutely hazardous waste per month.
2. What are the hazardous waste training requirements for Large Quantity Generators?
If you’re an LQG, specialized training is required for all your hazardous waste personnel within six months of bringing them onboard.
However, new hires can work under the direct supervision of a trained person for up to six months. Ditto for contractors: their employees can assist with your hazmat management if directly supervised by a trained person—but only once, and for a period of less than six months.
The EPA defines “hazardous waste personnel” as anyone on your staff whose actions—or inactions—might result in noncompliance with applicable RCRA regulations.
In other words, it’s anybody and everybody involved in selecting, marking, labeling, inspecting, moving, or otherwise fiddling with your hazardous waste containers.
Also note: whether they deal with hazardous waste daily or only incidentally, all your staff who do so must be adequately trained to RCRA standards, including personnel whom you might not think to consider.
For example, if someone in HR 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 be mindful that such training is required of any outside contractors who might help you with onsite hazardous waste management—or who might incidentally produce hazmat on your property (such as painters, repair companies, or renovators).
3. How should LQGs document their training efforts?
In a word: thoroughly. As an LQG, you’re required to maintain specific training records for your hazardous waste management personnel. The name, title, and job description for each must be extant with a detailed description of the amount and type of training he or she has received.
4. Who is considered a Small Quantity Generator of hazardous waste?
Per the EPA, you’re a Small Quantity Generator (SQG) if you generate more than 220 lbs. (100 kg.) but less than 2,200 lbs. (1,000 kg.) of hazardous waste per month; or less than 2.2 lbs. (1.0 kg.) of acute hazardous waste per month.
5. Who is considered a Very Small Quantity Generator of hazardous waste?
Per the EPA, you’re a Very Small Quantity Generator (VSQG) if you generate 220 lbs. (100 kg.) or less per month of hazardous waste; or 2.2 lbs. (1.0 kg.) or less of acute hazardous waste.
6. What are the training requirements for Small Quantity Generators?
As an SQG, your hazardous waste personnel need only be “thoroughly familiar” with proper waste handling and emergency response procedures, per the EPA.
So, although there’s no specific requirement for 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 probably not going to result in a Hallmark ending.
Minimally you should document dates and provide descriptions of hazmat training sessions for your personnel. Also, have sign‑in sheets to record which of your employees have attended them.
7. What are the training requirements for Very Small Quantity Generators?
The training requirements for VSQGs are the same as for SQGs. (See Q.6)
8. What exactly does hazmat training for LQGs involve?
For LQGs, your designated hazardous waste personnel must complete a program of classroom instruction, online training, and/or in-service training that enables them to ensure compliance with RCRA regulations.
Minimally, this includes training in emergency response procedures, application of emergency equipment, and the operation of emergency systems. And they must complete RCRA refresher training annually to remain in compliance.
However, whoever manages your entire hazardous waste program will likely need more training; and it’s solely up to you to ensure that all your personnel are adequately trained to maintain compliance with RCRA regulations.
Don’t go it alone. Get expert advice.
9. Are there state-specific rules for hazmat training?
Yes. Several states have additional or stricter requirements, so it’s essential to check local regulations.
10. Who can provide the required training for hazardous waste management?
Ironically enough, the EPA doesn’t approve, certify, or otherwise accredit people or programs for providing the breadth of specialized training required by the agency. Suffice to say, such training must be directed by a person trained in hazardous waste management procedures.
To traverse such a minefield, make sure the trainers you hire can present documentable evidence of extensive experience with hazardous waste management; that their instructors are experienced at teaching; and that they’re supported by research staff who keep them abreast of EPA regulations, which tend to be in bountiful and dynamic supply.
You can get expert advice & help here.
11. Where can you get expert help with employee hazmat and hazardous waste generator training requirements?
Hazardous Waste Experts can provide comprehensive training for your hazardous waste personnel, including specialized areas of hazardous waste management specific to particular industries and operations. (E.g., aviation fueling, site remediation, chemical & pharmaceutical compliance, food industry, and more.) Other training areas include:
- Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment
- Key parameters for automatic waste feed cutoff systems
- Communications and/or alarm systems
- Response to fires, explosions, and releases of hazardous waste constituents
- Response to groundwater contamination incidents
- Shutdown of operations
- Evacuation procedures
- Implementation of the facility contingency plan
- And more
Our instructors are not just experienced practitioners of hazardous waste management. They’re also superb teachers who are expert at imparting their knowledge to homogenous audiences: owners, managers, and all levels of employees.
They’re supported by research staff who keep them abreast of EPA regulations. And they can help you establish an ongoing training program to keep you in state and federal compliance.
Find out more here. Or call our new number: 425.414.3485.
And thank you for reading our blog!