LQGs and TSDFs must maintain a written description of who must receive training, the type of training to be given, and the subject matter covered in training. The hazardous waste facility owner or operator must maintain at the facility the following records and documents relevant to on-site training:
- The job title for each position at the facility related to hazardous waste management and the name of the employee filling each job.
- A written description of each position relating to hazardous waste at the facility. This description should be consistent in its degree of specificity with descriptions for other similar positions in the same company location or bargaining unit, but it must include the requisite skill, education, or other qualifications as well as duties of facility personnel assigned to each position.
- A written description of the type and amount of both introductory and continuing training that will be given to each employee filling the position.
- Records that document that the required training or job experience has been given to, and completed by, facility personnel.
How Long to Keep RCRA Training Records
Records must be kept documenting that training—whether classroom, on-the-job, or both—has been given to, and completed by, facility personnel. Training records for current employees must be kept until the closure of the facility. Training records of former employees must be kept for at least 3 years from the date the employee last worked at the facility. Personnel training records may accompany personnel transferred within the same company.
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On-the-Job Training
The type of training reflected in your records may be classroom training or on-the-job training. The federal regulations and some states require only one type of training. However, some states require both on-the-job and classroom training.
On-the-job training is often used to teach employees to work safely with hazardous wastes.
On-the-job training is usually “hands-on” and may include:
- Methods for collection;
- Segregation of waste and waste pickup;
- Proper selection and use of personal protective equipment;
- How to recognize the presence of hazardous chemicals;
- How to use facility systems;
- Location and use of spill cleanup equipment;
- Emergency response and evacuation routes; and
- How to fill out required documents and records.
On-the-job training is often conducted informally by supervisors. However, complete and accurate records must be kept.
Records should specify the name and job title of every employee receiving on-the-job training, along with a written description of the specific waste-handling tasks involved and an assessment of how well the employee performed the tasks.
Classroom Training
Classroom training is usually conducted in a formal setting with an instructor present to answer questions. This training is meant to provide generalized facility training to participants. In some states, the formal training requirement can be met by facility personnel using computer-based training programs. At a minimum, classroom training records should include:
- The name of the employee being trained;
- Date of the training;
- Training topic;
- The name of the trainer; and
- A brief outline of the subject matter covered.
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Additional Training Record Tips
Written training outlines or references to training materials may also be kept on file.
Since both initial and annual refresher training are required, it is a good idea to maintain a database of personnel who require training and the dates they attended. Such records can also assist in notifying personnel when refresher training is required.
Think about the training requirements for hazardous waste management personnel and the records required for each type of training. Review training requirements and training recordkeeping requirements for all hazardous waste management training conducted in your facility.
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