What are the training requirements under RCRA for Generators of hazardous waste?

RCRA training helps to protect employees, prevent spills, and avoid costly EPA penalties as they carry out tasks involving hazardous waste. This training informs employees of EPA standards (found in 40 CFR Part 262) that address on-site accumulations of hazardous waste through manifest tracking, labeling, record keeping and reporting requirements.

The type of training that must be conducted and extent of regulation that each generator must comply with depends on the volume of hazardous waste produced. Initially, a hazardous waste determination must be made. This applies to all generators of solid waste. Once a material is identified as hazardous, the generator must determine the extent of regulation to follow. CFR Part 261 details the identification and listing of hazardous wastes.

RCRA Training

Individuals who require this training perform hazardous waste related tasks, such as:

  • Characterizing and Identifying waste
  • Scheduling hazardous waste shipments
  • Inspecting hazardous waste storage and accumulation areas
  • Maintaining inventory and recordkeeping
  • Marking and labeling containers
  • Maintenance of tanks or other equipment
  • Any emergency coordination
  • Loading/unloading or transporting hazardous waste.

Large Quantity Generator Training Requirements. Found in 40 CFR 265.17

  • RCRA training must include emergency response information.
  • New employees have a six-month window to get the training they require. In the meantime, they cannot work unsupervised.
  • RCRA training requires an annual refresher course provided by the employer.
  • Training records must be maintained including name, job title, duties, education, and other qualifications.
  • Training records must be kept until closure and for three years beyond last date of employment.
  • Training may be in-person or online.  

Small Quantity Generator Training Requirements. Found in 40 CFR 262.16(b)(9)

  • The generator must ensure all employees are “thoroughly familiar” with proper waste handling and emergency response procedures. Employees must also be trained relevant to their duties.

Resources:

Online Training

Requirements Summary Table                  

40 CFR Part 265

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