RCRA - TRAINING/OTHER
To ensure proper handling of hazardous wastes and protection of workers, the Resource Conservation and Recovery Act (RCRA) outlines personnel training requirements for generators of hazardous waste, etching waste often being classified as a hazardous waste. The amount of hazardous waste a facility generates in a month ("generator status") dictates the level of training required.
RCRA hazardous waste regulations classify generators of hazardous waste into three categories based on the quantity generated, as follows:
- Conditionally exempt small quantity generators (CESQGs) generate no more
than 100 kilograms (220 pounds) of hazardous waste in a calendar month.
- Small quantity generators (SQGs) generate between 100 kilograms (220 pounds)
and 1,000 kilograms (2,200 pounds) of hazardous waste in a calendar month.
- Large quantity generators (LQGs) generate more than 1,000 kilograms (2,200
pounds) of hazardous waste in a calendar month.
The regulations refer to small quantity generators as "generators of greater than 100 kg but less than 1,000 kg in a calendar month." Requirements for "generators" always apply to large quantity generators, but may not apply to SQGs or CESQGs. Generator status is based on the monthly total of all hazardous waste generated rather than on the quantity of each type of hazardous waste. Generator status is not determined by average monthly hazardous waste generation. Rather, hazardous waste generator status is determined separately for each calendar month, based on actual hazardous waste generation in the month.
For LQGs, the following training requirements must be met:
- All facility personnel who are assigned to the management of hazardous waste must complete classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance with the hazardous waste management regulations.
- A person trained in hazardous waste management procedures must conduct the training program. The program instructions must cover procedures (including contingency plan implementation) specific to the position for which the personnel are employed.
- New employees must be trained within six months of hire or of their first assignment to a position requiring training. Further, they must not work unsupervised until the training has been completed (40 CFR 265.16(b)).
- Annual training reviews (refresher training) must be completed (40 CFR 265.16(c)).
- Training records for current employees must be maintained until the closure of the facility; for former employees, training records must be retained for a period of 3 years (40 CFR 265.16(e)). Records must be maintained for both classroom and on-the-job training administered.
- Each employer must maintain a training plan that includes the following (40 CFR 265.16(d)):
-- A job title and description for each position requiring training
-- The name of the employee filling the job
-- A written description of the type and amount of training each position will receive
-- Documentation that training was completed
According to 40 CFR 265.16(a)(3), the training must cover the following contingency planning and emergency response topics:
- Procedures for using, inspecting, repairing and replacing emergency and monitoring equipment.
- Key parameters for automatic waste feed cut-off systems
- Procedures for communicating with other employees and outside emergency response personnel
- Response to fire or explosion.
- Response to leaks or spills or groundwater contamination incidents.
- Shutdown of operations
Additional training topics typically include, but are not limited to, the following:
- Hazardous waste identification
- Container use, marking, and labeling
- Storage area management
- Personal health and safety and fire safety
- Manifesting and off-site transportation
For SQGs, the requirements are not as stringent and only basic training is required. Personnel must be trained so that they are thoroughly familiar with the waste handling and emergency procedures relevant to their position during normal facility operation and emergencies. (40 CFR 262.34) Though it is not a requirement of federal RCRA regulations, SQGs should maintain training records and documentation of training for a period of three years.
RCRA regulations do not have any formal training requirements for CESQGs of hazardous waste. However, it is strongly encouraged to train staff individuals who handle hazardous waste and retain records of the training provided.
For the complete text of the regulations (40 CFR 261, 262 and 265), click here:
40 CFR 261
40 CFR 262
40 CFR 265