RCRA Training Requirements Review

The alleged violations are:

• Failure to properly date, label, and manage hazardous waste containers;
• Failure to maintain records indicating the job title of each position at the facility related to hazardous waste management, and the name of the employee filling each job;
• Failure to obtain the signature from a representative of the disposal facility on four hazardous waste manifests within 60 days of shipment;
• Failure to conduct weekly inspections of its hazardous waste storage area;
• Failure to provide training to employees responsible for handling hazardous waste; and
• Failure to have a required contingency plan in place for a period of 2 years.

EPA says the settlement penalty reflects the company’s compliance efforts, and its cooperation with EPA in the resolution of this matter. As part of the settlement the company has not admitted liability for the alleged violations, but has certified its compliance with applicable RCRA requirements.

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Review of RCRA Training Requirements
It seems that these enforcement stories always include failure to train hazardous waste personnel. Why is this part of the regulation so difficult for companies to follow? Maybe it is because the rules on RCRA training are so complicated! Here’s the breakdown of what you have to do as a TSDF or by generator type.

Treatment, Storage, and Disposal Facilities (TSDFs)
(40 CFR 264.16 and 40 CFR 265.16)
TSDF personnel: Within 6 months of commencement of employment, or assignment to a new position at the facility (whichever is later), classroom instruction or on-the-job training relevant to the individual’s job and including emergency procedures, emergency equipment and systems; HAZWOPER training suffices if it meets all the RCRA emergency response training requirements. The program must include all the elements described in the facility’s written description of the type and amount of training given to each person in the facility record that lists each employee and his or her job title.
When transporting waste off-site or receiving waste, review the training requirements for Department of Transportation (DOT) Hazardous Materials Employees.
Refresher: Annually
Trainer qualifications: The person conducting the training must be trained in hazardous waste management procedures.

Remediation Waste Management Sites (RWMS)
(40 CFR 264.1(j))
RWMS personnel: Classroom or on-the-job training on how to respond effectively to emergencies and on how to perform their duties in a way that ensures the RWMS complies with the hazardous waste TSDF requirements that also apply to an RWMS. The training requirements of 40 CFR 264.16 are not applicable unless the RWMS is also subject to a traditional RCRA permit.
Refresher: Not specified
Trainer qualifications: Not specified

Large Quantity Generators (LQGs)
40 CFR 262.34(a)(4) and 40 CFR 265.16
Same training requirements as TSDF personnel. When transporting waste off-site, see the training requirements for DOT Hazardous Materials Employees.
Refresher: Annually
Trainer qualifications: The person conducting the training must be trained in hazardous waste management procedures.

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Small Quantity Generators (SQGs)
40 CFR 262.34(d)
Ensure facility personnel are thoroughly familiar with proper waste-handling procedures and emergency response procedures relevant to their responsibilities.
When transporting waste off-site, see the training requirements for DOT Hazardous Materials Employees.
Refresher: Not specified
Trainer qualifications: Not specified

Generators: Academic Laboratory Personnel
(40 CFR 262.207)
Training is required for all individuals working in a laboratory at the eligible academic entity. Training for laboratory workers and students must be commensurate with their duties so they understand the requirements of the Academic Laboratory Rule and can implement them.
Training methods can include: formal classroom training, electronic/written training, on-the-job training, instruction by the professor or laboratory manager before or during an experiment, or written or oral exams.
Refresher: Not specified
Trainer qualifications: None

Low Level Mixed Waste (LLMW)
40 CFR 266.230
The training of personnel who manage stored conditionally exempt LLMW must ensure that the conditionally exempt waste is safely managed and include training in chemical waste management and hazardous materials incidents response that meets the personnel training standards of 40 CFR 265.16(a)(3).
Refresher: Not specified
Trainer qualifications: None
These are the federal regulations. Your state may have stricter RCRA training requirements.

You have to keep records, too! See tomorrow’s Advisor for a training records checklist to make sure you are showing your work.