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This Fact File provides a training checklist for Large Quantity Generators (LQGs) of hazardous waste. LQGs have additional training requirements beyond those of Small Quantity Generators (SQGs), and it can be challenging to know whether your organization’s training program is compliant. This checklist will help you ensure that you are covering all the necessary elements of an LQG hazardous waste training program, including content, scheduling, and documentation.
Training requirements for LQGs are spelled out in 40 CFR 262.17(a)(7) and 265.16. In addition to the requirements for SQGs, which include ensuring that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations, LQGs have a few more requirements. These include:
This training can be conducted via classroom instruction, online training, hands-on training, or a combination of all three methods.
Use the following checklist to determine whether you are meeting all your compliance obligations in the three major areas of LQG hazardous waste training. What have you covered, and what is missing from your program?
Training content
Training schedule
Documentation
EPA says that employees at LQGs who receive OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) training under the regulations at 29 CFR 1910.120 may not need additional RCRA emergency response training for hazardous waste management. This only applies to emergency response training; employees must still be trained to handle the specific wastes at the facility.
40 CFR 262.17(a)(7) – Conditions for exemption for a large quantity generator that accumulates hazardous waste: Personnel training
40 CFR 265.16 – General Facility Standards: Personnel training
“Large Quantity Generators (LQGs)” means facilities that generate more than 1,000 kg of nonacute hazardous waste per calendar month, or more than 100 kg of residues from a cleanup of acute hazardous waste in a calendar month, or more than 1 kg of acutely hazardous waste per calendar month.
“Hazardous waste” means waste with properties that make it dangerous or capable of having a harmful effect on human health and the environment. Under the Resource Conservation and Recovery Act (RCRA), hazardous wastes are specifically defined as wastes that meet a particular listing description or that exhibit a characteristic of hazardous waste.
Hazardous waste generators must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and during emergencies. Large Quantity Generators (LQGs) of hazardous waste have more requirements than Small Quantity Generators (SQGs) related to personnel training content, scheduling, and recordkeeping.
A facility has decided to revamp their hazardous waste employee training program. The production management team is encouraging the EHS manager to find a training that is all online. This would reduce the cost of training and allow more scheduling flexibility around when the training course can be completed. The EHS manager did some evaluation and came back to the management team advising against going completely online with their training course.
The EHS manger determined that online training alone isn’t recommended to be sufficient in meeting all the required training elements. Employees must be trained in the specific wastes, waste management practices, and emergency procedures at an individual facility, and online training programs don’t address the level of detail necessary. As a compromise, the facility was able to use online training for many of the training elements and paired it with classroom and hands-on components to fully meet the facility-specific elements.
This Fact File provides a training checklist for Large Quantity Generators (LQGs) of hazardous waste. LQGs have additional training requirements beyond those of Small Quantity Generators (SQGs), and it can be challenging to know whether your organization’s training program is compliant. This checklist will help you ensure that you are covering all the necessary elements of an LQG hazardous waste training program, including content, scheduling, and documentation.
Training requirements for LQGs are spelled out in 40 CFR 262.17(a)(7) and 265.16. In addition to the requirements for SQGs, which include ensuring that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations, LQGs have a few more requirements. These include:
This training can be conducted via classroom instruction, online training, hands-on training, or a combination of all three methods.
Use the following checklist to determine whether you are meeting all your compliance obligations in the three major areas of LQG hazardous waste training. What have you covered, and what is missing from your program?
Training content
Training schedule
Documentation
EPA says that employees at LQGs who receive OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) training under the regulations at 29 CFR 1910.120 may not need additional RCRA emergency response training for hazardous waste management. This only applies to emergency response training; employees must still be trained to handle the specific wastes at the facility.
40 CFR 262.17(a)(7) – Conditions for exemption for a large quantity generator that accumulates hazardous waste: Personnel training
40 CFR 265.16 – General Facility Standards: Personnel training
“Large Quantity Generators (LQGs)” means facilities that generate more than 1,000 kg of nonacute hazardous waste per calendar month, or more than 100 kg of residues from a cleanup of acute hazardous waste in a calendar month, or more than 1 kg of acutely hazardous waste per calendar month.
“Hazardous waste” means waste with properties that make it dangerous or capable of having a harmful effect on human health and the environment. Under the Resource Conservation and Recovery Act (RCRA), hazardous wastes are specifically defined as wastes that meet a particular listing description or that exhibit a characteristic of hazardous waste.
Hazardous waste generators must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and during emergencies. Large Quantity Generators (LQGs) of hazardous waste have more requirements than Small Quantity Generators (SQGs) related to personnel training content, scheduling, and recordkeeping.
A facility has decided to revamp their hazardous waste employee training program. The production management team is encouraging the EHS manager to find a training that is all online. This would reduce the cost of training and allow more scheduling flexibility around when the training course can be completed. The EHS manager did some evaluation and came back to the management team advising against going completely online with their training course.
The EHS manger determined that online training alone isn’t recommended to be sufficient in meeting all the required training elements. Employees must be trained in the specific wastes, waste management practices, and emergency procedures at an individual facility, and online training programs don’t address the level of detail necessary. As a compromise, the facility was able to use online training for many of the training elements and paired it with classroom and hands-on components to fully meet the facility-specific elements.