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When you think of RCRA, you think of manifests, “cradle to grave” hazardous waste management, transportation, container management, and endless hours of recordkeeping.
However, one important aspect of RCRA for EHS managers is training. There are specific training requirements for personnel at hazardous waste TSDFs and large quantity generators (LQGs). Small quantity generators (SQGs) are required to ensure that facility personnel are thoroughly familiar with proper waste-handling procedures and emergency response procedures relevant to their responsibilities.
TSDF and LGQ employees who are regularly exposed to an area where hazardous waste is generated, treated, stored, or shipped must complete RCRA classroom training or on-the-job training from a qualified trainer. A person qualified to perform training is someone who has been trained in hazardous waste management procedures and RCRA contingency plan implementation.
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The training must ensure that facility personnel are able to respond to, use, inspect, repair, or replace emergency and monitoring equipment, and emergency procedures and emergency systems.
Specifically, training should address:
- Automatic waste feed cut-off systems
- Procedures for using, inspecting, repairing, and replacing emergency and monitoring equipment
- Communication or alarm systems
- Response to fires or explosions
- Response to groundwater contamination incidents
- Shutdown of operations
New employees may work in hazardous waste operations for up to 6 months without completion of required training and only under the supervision of a trained person. All employees are required to review training on a yearly basis.
When transporting waste off-site or receiving waste, TSDFs, LQGs, and SQGs should review, and implement if necessary, the Department of Transportation’s training requirements for hazardous materials employees.
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Check with Your State
Remember: These are federal regulations, and states and territories are free to impose stricter requirements. Therefore, as with anything RCRA-related, check with your state.