Hazardous waste personnel training

Scope

Under RCRA, Small and Large Quantity Generators must provide training to all employees who handle hazardous waste. Basic hazardous waste training is a best practice for Very Small Quantity Generators. Hazardous waste training must be job-function specific, meaning it must be tailored to the specific wastes the employee will be exposed to and the specific procedures used at the facility.

Regulatory citations

• 40 CFR 262.16 and .17
• 40 CFR 265.16

Key definitions

• Acute hazardous waste: is any hazardous waste with a “P” waste code (or certain “F” waste codes). These wastes are subject to stringent accumulation and management requirements.
• Accumulate: means to store hazardous waste on-site for a regulated amount of time before shipping it off-site. Generators have accumulation time limits as well as quantity limits.
• Central Accumulation Area (CAA): is an area where a hazardous waste generator collects marked and dated hazardous waste. Waste in a CAA may only be accumulated for 90 days or 180 days, depending on the generator’s hazardous waste category.
• Counting: means totaling the hazardous wastes at a given facility for a particular month in order to determine hazardous waste generator status.
• EPA identification number: is the unique number assigned by EPA to each hazardous waste generator, transporter, or treatment, storage, and disposal facility.
• Episodic generation: is the situation in which a generator’s status changes from one month to the next, as determined by the amount of waste generated in a particular month. If a generator’s status does in fact change, the generator is required to comply with the respective regulatory requirements for that class of generators for the waste generated in that particular month.
• Generator: is any person, by site, whose act first creates or produces a hazardous waste or used oil, or first brings such materials into RCRA regulation.
• Hazardous waste: refers to waste with properties that make it dangerous or capable of having a harmful effect on human health and the environment. Under RCRA, hazardous wastes are specifically defined as wastes that meet a particular listing description or that exhibit a characteristic of hazardous waste.
• Large Quantity Generators (LQGs): are facilities that generate more than 1,000 kilograms of hazardous waste per calendar month, or more than 1 kilogram of acutely hazardous waste per calendar month.
• Listed wastes: are wastes that are considered hazardous under RCRA because they meet specific listing descriptions. These lists are found in 40 CFR 261, Subpart D.
• Manifest: also known as the universal hazardous waste manifest, refers to the paperwork that accompanies hazardous waste from the point of generation to the point of ultimate treatment, storage, or disposal. Each party involved in the waste’s management retains a copy of the RCRA manifest, which contains specific information about the waste.
• RCRA: refers to the Resource Conservation and Recovery Act, which is the nation’s solid and hazardous waste management law.
• Small Quantity Handler of Universal Waste (SQHUW): is a handler that does not accumulate more than 5,000 kilograms of all universal waste categories combined at a location at any one time.
• Tanks: are stationary containers used to store or treat hazardous waste.
• Very Small Quantity Generator (VSQG): is a generator who never accumulates more than 2,200 pounds of hazardous waste or 2.2 pounds of acute hazardous waste at any one time (formerly known as Conditionally Exempt Small Quantity Generator (CESQG)).

Summary of requirements

• Ensure all employees are thoroughly familiar with proper waste handling procedures relevant to their responsibilities.
• Ensure employees are trained in the specific hazards of the waste they handle.
• Ensure employees are familiar with emergency notification procedures at the facility.
• Ensure employees know how to respond to an emergency at the facility.
• Ensure employees are familiar with the emergency equipment at the facility.