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Hazardous waste training: A checklist for Large Quantity Generators (LQGs)

Introduction

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.

Background

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:

  • More specific training regarding emergency procedures, equipment, and systems;
  • A defined schedule for completion of hazardous waste training programs for new employees and reviews for existing employees; and
  • Recordkeeping that demonstrates completion of training as well as documentation of job titles related to hazardous waste, the training required for each job, and the names of the employees in each position.

This training can be conducted via classroom instruction, online training, hands-on training, or a combination of all three methods.

Large Quantity Generator (LQG) training checklist

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

  • Do your facility personnel receive classroom instruction, online training, and/or on-the-job training on the specific waste at the facility and their waste management functions?
  • Does the training cover all the elements described in the written training program?
  • Is the program directed by a person trained in hazardous waste management procedures?
  • Does the instruction teach facility personnel hazardous waste management procedures (including contingency plan implementation) that apply to the positions in which they are employed?
  • Does the training program enable facility personnel to respond effectively to emergencies?
  • Does the training program familiarize employees with emergency procedures, emergency equipment, and emergency systems, including, where applicable:
    • Procedures for using, inspection, repairing, and replacing facility emergency and monitoring equipment;
    • Key parameters for automatic waste feed cut-off systems;
    • Communications or alarm systems;
    • Responses to fires or explosions;
    • Response to groundwater contamination incidents; and
    • Shutdown of operations.

Training schedule

  • Do your facility personnel successfully complete the program within six months after the date of their employment or assignment to a facility, or to a new position at a facility?
  • Do you prohibit new employees from working in unsupervised positions until they complete the training requirements?
  • Do new employees work under supervision until they complete their training?
  • Do your facility personnel participate in an annual review of the initial training?

Documentation

  • Do you maintain the following documents and records at the facility?
    • The job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job;
    • A written job description for each position related to hazardous waste management (This description may be consistent in its degree of specificity with descriptions for other similar positions in the same company location or bargaining unit, but must include the required skills, education, or other qualifications, and duties of facility personnel assigned to each position.);
    • A written training program, describing the type and amount of both introductory and continuing training that will be given to each person filling a position related to hazardous waste management; and
    • Records to document that the required training or job experience has been given to, and completed by, facility personnel.
  • Do you keep training records on current personnel, as required, until closure of the facility?
  • Do you keep training records on former employees for at least three years from the date the employee last worked at the facility?

Compliance tip

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.

Applicable laws & regulations

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

Related definitions

“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.

Key to remember

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.

Real world example

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.