an expert's guide to rcra training

An Expert’s Guide to RCRA TrainingHow Costly Impacts Can Be Avoided

with Hazardous Waste Training.

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Meet Your PresenterDoug Graham, CHMMSr. EH&S Consultant & External Training [email protected]

22 Years training hazardous waste generators in 12 states

mailto:[email protected]

DisclaimerThis webinar is not a RCRA training

course. Rather, it is a guide to understanding the requirements around

RCRA training.

Our Key MessageRCRA Training Requirements are

Often State-Specific; Documentation and proper coverage is crucial to avoid what are common

violations

Who Is This For?EH&S

Managers

Overall Compliance

Employees with Waste

Responsibilities

Individual Compliance

Human Resources

Training & Recordkeepin

g

This Is Why We’re Different

What Others Say

Training is about “checking the box”

RCRA training- 5 minutes and you’re

done… easy

It’s all the same stuff - the trainer doesn’t matter

What We Say Instead

Training is about maintaining compliance

The requirements are state-specific and affect

employees’ roles differently

Experience, perspective, and the ability to engage

employees matter

OBJECTIVELearn who needs Hazardous

Waste (RCRA) training, including how much, how often, what to

cover, and other regulatory requirements

Key TakeawaysApplicable to employees who perform

hazardous waste-related tasks

Requirements vary by state and generator status (size)

Required annually for some generators

Curriculum determined by tasks performed

AgendaTraining Overview: Who

Needs It and How Much?

Federal Training Requirements

State Authorized RCRA Programs

Potential Consequences of Falling Short

Training in the. . .U.S. Environmental Protection Agency (EPA) Hazardous

Waste Regulations (40 CFR 260-271)

And, if applicable, state-specific hazardous waste regulations

Who are the facility personnel who need training?

Those with RCRA-related job duties, including:

• Identifying and characterizing wastes • Completing waste information profiles• Interacting with government officials• Scheduling waste shipments• Performing accumulation area inspections• Performing hazardous waste tank inspections• Maintaining inventory logs• Recordkeeping• Completing and/or signing manifests• Completing annual/biennial reports

• Marking and labeling of containers• Maintaining the main accumulation/storage area• Maintaining tanks• Maintaining satellite containers • Arranging hazardous waste shipments • Assisting with routine compliance issues • Managing residue containers• Reporting releases of hazardous constituents• Responding to releases• Acting as an emergency coordinator• Loading or transporting hazardous waste

Those with RCRA-related job duties, including:

Who are the facility personnel who need training? (Cont’d)

Let’s Break it DownWho? How Much?

How Often?

Curriculum? Instructor?Recordkeeping?

By Generator Size: LQG, SQG, CESQG

Federal Large Quantity Generator (LQG) Training Requirements40 CFR 265.16 (from 262.34(a)(4))

Key Regulatory Points (paraphrased):265.16(a)(1)- Facility personnel must successfully complete a program of instruction265.16(a)(2)- Directed by a person trained in hazardous waste management265.16(a)(2)- Teaches procedures relevant to their job position265.16(a)(3)- Must include emergency response procedures265.16(a)(4)- HAZWOPER training may substitute for 265.16(a)(3)265.16(b)- New employees trained within 6 months, and not unsupervised in the interim265.16(c)- Annual review of the initial training (refresher)265.16(d)-(e)- Training records

Applicable to “facility personnel” who perform hazardous waste-related duties

LQG

Federal Training Requirements40 CFR 265.16

LQG

“Successfully completed” implies the employer has established a standard for success, (e.g.,

participation, involvement, testing, etc.). “ensures the facility’s compliance” implies that the training

be performance-based. Style of training (classroom, computer-based, hands-on) is flexible

(a)(1) Facility personnel must 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 with the requirements of this part. The owner or operator must ensure that this program includes all the elements described in the document required under paragraph (d)(3) of this section.


LQG

(a)(2) This program must be directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed.

This clause establishes the qualifications of the instructor being at a minimum a person who has

been trained themselves.


LQG

(a)(2) This program must be directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed.

This clause provides that training need only cover those requirements that affect an employee’s

specific duties and that non-applicable topics need not be covered.


LQG

(a)(3) At a minimum, the training program 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, including where applicable:(i) Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment;(ii) Key parameters for automatic waste feed cut-off systems;(iii) Communications or alarm systems;(iv) Response to fires or explosions;(v) Response to ground-water contamination incidents; and(vi) Shutdown of operations.

This clause requires that RCRA training include site-specific emergency response information, such

as the specifics of the facility’s contingency plan.


LQG

Because emergency response training is already required under the OSHA HAZWOPER standard (29

CFR 1910.120(q)), that training will cover the emergency-related topics required under RCRA.

(a)(4) For facility employees that receive emergency response training pursuant to Occupational Safety and Health Administration (OSHA) regulations 29 CFR 1910.120(p)(8) and 1910.120(q), the facility is not required to provide separate emergency response training pursuant to this section, provided that the overall facility training meets all the requirements of this section.


LQG

This establishes a 6-month window to get new employees trained as long as they do not work

unsupervised during that pre-training period

(b) Facility personnel must successfully complete the program required in paragraph (a) of this section within six months after the effective date of these regulations or six months after the date of their employment or assignment to a facility, or to a new position at a facility, whichever is later. Employees hired after the effective date of these regulations must not work in unsupervised positions until they have completed the training requirements of paragraph (a) of this section.


LQG

(c) Facility personnel must take part in an annual review of the initial training required in paragraph (a) of this section.

Refresher training is required annually.


LQG

(d) The owner or operator must maintain the following documents and records at the facility:(1) The job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job;(2) A written job description for each position listed under paragraph (d)(1) of this Section. This description may be consistent in its degree of specificity with descriptions for other similar positions in the same company location or bargaining unit, but must include the requisite skill, education, or other qualifications, and duties of facility personnel assigned to each position.

Training record must be maintained onsite and include: name, job title, specific hazwaste duties, requisite skill, education, or other qualifications.


LQG

(d)(3) A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position listed under paragraph (d)(1) of this section;(4) Records that document that the training or job experience required under paragraphs (a), (b), and (c) of this section has been given to, and completed by, facility personnel.(e) Training records on current personnel must be kept until closure of the facility. Training records on former employees must be kept for at least three years from the date the employee last worked at the facility. Personnel training records may accompany personnel transferred within the same company.

Additionally, a written description of type and amount of training and documentation the training

was completed. The records for current employees must be maintained until closure and for 3 years beyond the date of last employment.

Federal Small Quantity Generator (SQG) Training Requirements262.34(d)(5)(iii)

SQG

(iii) The generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies;

Federal Conditionally Exempt Small Quantity Generator (CESQG) Training Requirements

CESQG

There are no training requirements for CESQGs on a federal level, however

employers are well advised to educate their employees as to the applicable regulations

What About My State?

State Authorized RCRA ProgramsState programs may adopt the federal training

requirements, or adopt more stringent requirements

State Authorized RCRA ProgramsStep 1: Determine your generator status as

defined by your state.

States may define generator status differently than the EPA, sometimes even using different names (e.g., “full quantity generator”, “fully-regulated generator”, “SQG-Plus”, “VSQG”,

etc.)

The training requirements are often different based on that state generator size

classification.

State Authorized RCRA ProgramsStep 2: Read the specific training requirements in

the section of the state regulations addressing your generator size classification.

Variations in the specific training provisions in individual state programs can be vastly

different.

State Authorized RCRA ProgramsSome Regional Examples (East Coast)

• In New Hampshire, in addition to the training of employees, all Full Quantity Generators (federal LQGs and SQGs) must have at least one onsite “Hazardous Waste Coordinator” trained and certified by the NHDES.

• In Rhode Island, the RIDEM mandates that LQGs and SQGs follow very specific curriculum, documentation, and instructor qualification provisions that far exceed the EPA’s.

• Maryland requires SQGs to also follow the federal LQG training requirements (SQGs and LQGs are called “Fully-Regulated Generators” in Maryland).


Improper disposal resulting in contamination of the

environment

Long-term liability (potentially responsible

party status)

Civil penalties up to $37,500 per violation, per

day (or more, in some states)

Conclusion

It’s up to the generator to make sure all affected employees are trained relative to their

responsibilitiesAND to know their state-specific requirements.

Other Training RequirementsOther training requirements typical for EH&S professionals include:

• Emergency Response (HAZWOPER)

• DOT Hazardous Materials Training• IATA Dangerous Goods Training (Air)

15 Separate OSHA Standards, including• Hazardous Chemicals in Laboratories• Control of Hazardous Energy (Lockout-Tagout)• Confined Spaces• Bloodborne Pathogens• Electrical Safety• Hazard Communication• Access to Exposure and Medical Records• Cranes• Powered Industrial Trucks• Portable Fire Extinguishers• Employee Emergency Plans• First Aid

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an expert's guide to rcra training

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