RCRA Training: Who Needs It?

All Facilities

Applicants for a permit to operate a hazardous waste facility must include in the permit application a written outline of both the introductory and continuing training programs by owners or operators to prepare persons to operate or maintain the facility safely.

Large Quantity Generators (LQGs)

LQGs that accumulate hazardous waste on-site for 90 days or less without a permit must comply with the same personnel training requirements that apply to hazardous waste TSDFs. A generator who accumulates hazardous waste for more than 90 days is an operator of a storage facility and must comply with the training requirements for TSDFs.

Treatment, Storage, and Disposal Facilities (TSDFs)

TSDFs must train employees within 6 months of the commencement of their employment or assignment to a new position at the facility. They must conduct refresher training for employees annually.

TSDF personnel must successfully complete a program of classroom instruction or on-the-job training designed to ensure the facility’s compliance with EPA regulations. There should be an opportunity for interactive questions and answers with the person conducting the training session. The training should be relevant to the individual jobs at the facility and must include information to familiarize employees with emergency procedures, equipment, and systems, including:

  • Using, inspecting, repairing, and replacing emergency and monitoring equipment
  • Key parameters for automatic waste feed cutoff systems
  • Communications or alarm systems
  • Response to fire or explosions
  • Response to groundwater

Small Quantity Generators (SQGs)

SQGs are not required to have a formal written training program for their employees. SQGs are required, however, to ensure that facility personnel are thoroughly familiar with proper waste-handling procedures and emergency response procedures relevant to their responsibilities during normal facility operations and emergencies.

Conditionally Exempt SQG (CESQG)

There are no formal training requirements for CESQGs (generates less than 220 pounds per month) in the federal regulations. However, some states regulate all generators and have stricter training requirements.