Hazardous Waste Management, Training

Does Your Shipping/Receiving Clerk Need Hazardous Waste Training?

Question: If our shipping and receiving clerk is the person who receives our compressed gas tanks and they sign the manifest, do they need to be trained in Hazardous Waste Regulations RCRA or is training in just DOT ok?

Shipping manifest

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Answer: As you note, hazardous materials training (as specified in 49 CFR 172.704) is required for the representative of a facility that signs a hazardous waste manifest to certify receipt or rejection of a hazardous waste shipment. You have also told us that this employee is not involved in the preparation of a hazardous waste manifest as a generator and that your facility is not a permitted (or interim status) hazardous waste treatment, storage, or disposal facility.

We are not aware of any RCRA requirements that specify RCRA training for an employee serving in the capacity that you have described. That said, the manifest regulations that were revised this year in connection with the launch of the new e-manifest system clarify that a “receiving facility” (which would include yours) must comply with the “use of manifest” requirements (40 CFR 264.71) and the “manifest discrepancies” requirements (40 CFR 264.72) in connection with state-only as well as federally regulated hazardous waste shipments. It is not specifically stated in the regulations but compliance with these requirements would seem to necessitate that an employee that signs a manifest upon receipt of a shipment would need to be trained in such matters as being able to ascertain whether the waste received (e.g. quantity and type) matches that designated on the manifest.

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