In order to manage the wastes safely and properly, your workers at sites that handle them must be trained in waste management techniques and how to respond appropriately to releases that occur. But your training efforts are wasted if you can prove that workers completed it. Keeping good training records is not only good practice, it’s required.

Your RCRA training records must include:

• The job title of each hazardous waste position at the facility and the name of the person filling the position
• A written job description for each position at the facility, including requisite skill, education, or other qualifications and duties of employees assigned to each position
• Documentation that the required training has been given to facility personnel

You have to keep training records for current personnel until closure of your facility. For former personnel, training records must be maintained for 3 years from the employee’s last date of employment.

Training records should be kept showing when the training was held, what was covered, who gave the training and the trainer’s qualifications, and who attended.

Enforcement

Some of the most frequently cited violations by state and federal inspectors at hazardous waste generator facilities involve recordkeeping, or lack thereof, for hazardous waste training. Violations include lack of job descriptions, incomplete documentation of the type and amount of training provided and/or records verifying that training was conducted (e.g., employee sign-in sheets and/or quizzes).

What About State Requirements?

No states have adopted employee training rules for hazardous waste generators and treatment, storage, and disposal facilities that are significantly stricter than federal training rules. Many states, however, have adopted rules for how such facilities manage hazardous wastes that are stricter than federal rules, and therefore may affect the content of specific training sessions. Be sure to check your state’s rules for any differences.