(This checklist includes requirements for small quantity generators of hazardous waste, which are not covered under 40 CFR 264.16 and 40 CFR 265.16.)
Do you generate RCRA hazardous waste?
If yes, are you a conditionally exempt small quantity generator (CESQG) (under federal definition, the generator of 100 kilograms (kg) or less per month of nonacute hazardous waste and 1 kg or less of acute hazardous waste)?
If yes, you are not subject to these RCRA training requirements.
Are you a small quantity generator (SQG) (under federal definition, the generator of more than 100 kg but less than 1,000 kg of hazardous waste per month and 1 kg or less of acute hazardous waste per month)?
If yes, do you accumulate hazardous waste on-site before it is shipped to a treatment, storage, and disposal facility (TSDF)?
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If yes, have you made sure that (under 40 CFR 262.34(d)) “all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies”?
If you are a large quantity generator (LQG) (under federal definition, a generator of 1,000 kg or more of hazardous waste per month or more than 1 kg of acute hazardous waste), do you accumulate hazardous waste on-site?
If yes, have you trained “facility personnel” in the following areas (40 CFR 264.16(a)(3) and 40 CFR 265.16(a)(3)):
- Key parameters for automatic waste-feed cutoff systems?
- Communications or alarm systems?
- Response to fires or explosions?
- Response to groundwater contamination incidents?
- Shutdown of operations?
Have you made sure that new employees or workers that have been newly assigned to this position have completed this training within 6 months of taking this job or new position (40 CFR 264.16(b) and 40 CFR 265.16(b))?
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Have you made sure that these new or newly assigned workers do not work in unsupervised positions until they have completed this training (40 CFR 264.16(b) and 40 CFR 265.16(b))?
Do “facility personnel” take part in an annual review of this training (40 CFR 264.16(c) and 40 CFR 265.16(c))?
Does the owner/operator keep the following documents and records at the facility (40 CFR 264.16(d) and 40 CFR 265.16(d))?
- The job title for each hazardous waste–related position at the facility, and the name of the person who fills that position?
- A written job description for each of these positions that includes the requisite skill, education, or qualifications, and duties of each position?
- A written description of the type and amount of training given to each of these hazwaste workers?
- Records that document that these workers have received and completed the training required by 40 CFR 264.16 and 40 CFR 265.16?
Have you kept training records on current personnel until facility closure or on former personnel for at least 3 years from the date the employee last worked at the facility? (40 CFR 264.16(e) and 40 CFR 265.16(e))?
Note: The training requirements of 40 CFR 264.16 and 40 CFR 265.16 apply to owners and operators of permitted and interim status hazardous waste TSDFs as well as to LQGs.
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