Does DOT Require Training for Universal Waste Handlers? Yes!

EPA Regs for Universal Waste

Small quantity handlers of universal waste (less than 5,000 kg of accumulated waste at any one time) 40 CFR 273.16: SQHUWs must inform all employees who handle or have responsibility for managing universal wastes of proper handling and emergency procedures appropriate to the type of universal waste handled at the facility.

Large quantity handlers of universal waste waste (5,000 kg or more of accumulated waste at any one time) 40 CFR 273.36: LQHUWs must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relative to individual responsibilities during normal facility operations and emergencies.

Some universal wastes are regulated by DOT as hazardous materials because they meet the criteria for one or more hazard classes specified in 49 CFR 173.2. Consequently, transporters of such universal wastes are required to comply with all applicable DOT hazardous material rules, including the training requirements.

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DOT Training Requirements

• Hazardous Materials Drivers 49 CFR 177.816: Training in the safe operation of their vehicles. Refresher training every 3 years

• Hazardous Materials Employees 49 CFR 172.702 and 49 CFR 172.704: All Hazardous Materials employees must receive one or more types of training depending on their job duties. Refresher training is required every 3 years.

• General awareness: Required for all employees with any hazardous materials transportation responsibilities

• Security awareness training: Training must provide an awareness of security risks associated with hazmat transportation and methods designed to enhance transportation security.

• Function-specific: Training covering the particular knowledge, skills, and abilities each individual needs to do his or her hazardous materials transport tasks properly and safely

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• Safety: Training required for employees who handle or transport packages containing hazardous materials, including warehouse workers, and drivers who would be exposed to hazardous materials if they were in an accident

• Drivers: In addition to first three levels of training, special training that meets FMCSA regulations pertaining to vehicle inspection and operation; conditions affecting vehicle handling; and crossing tunnels, bridges, and railroads

• In-depth security: Training concerning the security plan and its implementation for all hazardous materials employees of companies required to have a security plan.

• HAZWOPER: Required for employees required to drive onto hazardous waste sites, enter EPA-regulated TSDF, or respond to hazardous waste emergencies.