Training Your Hazardous Waste Personnel Must Take

The Environmental Protection Agency (EPA) established a comprehensive regulatory program in 1976 to ensure that hazardous waste is managed correctly from the time it is created, through transport, treatment, storage, and until it is disposed. The Resource Conservation and Recovery Act (RCRA) provides the framework for hazardous waste management and qualified states are authorized to administer and enforce the RCRA program within the state.

It’s important that you manage your hazardous waste in accordance with all state and federal regulations. The degree of regulation that applies is dependent on the amount of waste you produce; however, anyone who generates, accumulates, stores, transports, or treats hazardous waste must receive training. When rules change, updated training should be provided. Your hazardous waste personnel are required to complete appropriate training to become familiar with proper hazardous waste management as well as emergency procedures for wastes handled at your facility.

State Training Requirements

Training is required for any of your facility personnel whose duties have a direct effect on hazardous waste management and/or hazardous waste accumulation. This includes not only employees who come in direct contact with your hazardous waste in their duties (such as filling and maintaining drums or tanks), but also anyone who conducts hazardous waste management activities — such as employees who:

• profile (identify and characterize) hazardous waste
• apply regulations/assist with compliance issues
• oversee waste personnel or operations

The training program must ensure that your facility maintains compliance with requirements during normal operations and emergencies. Required documentation includes a written description of the training and a record of when it was administered and completed. These records must be maintained on-site for at least three years from the date the employee last worked for you, should they leave.  

Types of Training

The amount of training depends on your employee’s specific job duties and can be accomplished through classroom, online, or on-the-job training. Obviously, the person who oversees your hazardous waste program may require more training than an employee who does routine hazardous waste tasks.

OSHA Training

The Occupational Safety and Health Administration (OSHA) was created to ensure worker and workplace safety and OSHA standards require that you train your employees in the safety and health aspects of their jobs to ensure that they do not get hurt. Hazardous waste personnel can be exposed to many risks associated with OSHA violations, such as potential chemical exposures, fire and electrical hazards, respiratory hazards, and others.  

Hazardous Communication Standard (HCS)

OSHA requires the implementation of a hazard communications program for all employers who have hazardous chemicals in their workplace. The standard is designed to protect against chemical source illnesses and injuries by ensuring that employers and employees are provided with sufficient information to recognize chemical hazards and take appropriate protective measures.*

Content Covered

Covers the “Right-to-Know” laws and how to identify hazardous chemicals, including understanding the information provided on chemical container labels and material safety data sheets.

Who Should Take

All workers who may be exposed to or handle hazardous chemicals and employees responsible for developing and/or managing the hazard communication program for your facility.

*This training is included as part of the HAZCOM standard:

Personal Protective Equipment (PPE)

Content Covered

The training reviews a variety of PPE, including items such as gloves, foot and eye protections, hard hats, respirators, and full body suits. It includes how it’s used to prevent exposure and how to dress, wear, and remove it safely to prevent secondary contamination.

Who Should Take

PPE training is mandatory for anyone with a risk for potential injury from workplace hazards.

Fire Prevention and Fire Extinguisher Types

Content Covered

OSHA requires all employers to maintain compliant fire prevention plans and the training includes a thorough review of the entire plan, including how to identify and correct potential fire hazards.

Who Should Take

All employees should take this training.

OSHA provides a model training program for hazard communication that can help you tailor a program to fit your needs.

DOT Hazardous Materials Transportation Regulations

When you ship hazardous waste off-site, the transport is regulated by the United States Department of Transportation (DOT). The goal of DOT training is to ensure that hazardous waste is properly packaged and labeled for shipment off site for treatment, storage, or disposal. The uniform hazardous waste manifest is an EPA document that doubles as a DOT shipping paper during transport and employees must be trained in DOT hazmat transportation in order to sign the manifest.

Content Covered

Employees will learn about:

• Identification of hazardous materials
• Proper packaging of materials (including labeling and package selection)
• Required shipping papers
• Providing emergency instructions
• Security awareness

Who Should Take

All employees involved in the shipment of hazardous materials including the designated manifest signer and compliance point-person.

RCRA Training

The EPA defines RCRA Personnel as any employee whose actions or failure to act can result in non-compliance. RCRA training teaches personnel how to do their jobs in a way that maintains compliance with the EPA’s hazardous waste rules. Small quantity generators must train personnel so that they are thoroughly familiar with the RCRA rules,

The EPA requires RCRA training for anyone who handles or manages hazardous waste and provides training modules that overview specific regulatory topics. The EPA does not specify duration of training for small generators; however, as a best management practice you must train personnel so that they are thoroughly familiar with RCRA rules, including providing update training when rules change. The EPA’s training modules are a great way to accomplish that. We’ve compiled a list of the ones that will be most helpful for your hazardous waste personnel.

Generators

Content Covered

This training covers the definitions and regulations that apply to generators of hazardous waste. It includes the use of EPA identification numbers and manifests, the three classes of generators and accumulation limits, and recordkeeping and reporting requirements.

Who Should Take

Any employee tasked with container management as well as your compliance point-person.

Hazardous Waste Identification

Content Covered

This training explains the definition of hazardous waste and the hazardous waste identification process. Concepts that are covered include hazardous waste listings, hazardous waste characteristics, the “mixture” and “derived-from” rules, the “contained-in” policy, and the Hazardous Waste Identification Rules (HWIR).

Who Should Take

Any employee with potential exposure to hazardous waste and your facility’s designated compliance point-person.

Containers

Content Covered

This training reviews two sets of regulatory requirements for containers, including those pertaining to the management of hazardous waste containers and those governing residues of hazardous wastes in empty containers.

Who Should Take

Any employee tasked with container management as well as your compliance point-person.

Solid Waste and Hazardous Waste Exclusions

Content Covered

This training explains each waste exclusion and its scope, to help determine whether or not a given waste is regulated under RCRA.

Who Should Take

Any employee tasked with hazardous waste profiling as well as your compliance point-person.

Definition of Solid Waste and Hazardous Waste Recycling

Content Covered

This training explains thoroughly defines solid waste and explains the standards governing the recycling and management of specific types of waste. The conditions under which hazardous waste-derived products may be excluded from regulations are covered as well as recycling requirements, including special recycling standards for spent lead-acid batteries and other materials.

Who Should Take

Any employee tasked with container management as well as your compliance point-person.

Enforcement and Compliance

Content Covered

EPA and the states monitor hazardous waste handlers and take legal action when noncompliance is detected. Learn about enforcement procedures, types of enforcement actions, and EPA’s compliance incentive and assistance policies.

Who Should Take

Your compliance point-person. Other available RCRA Training Modules that might be pertinent for your facility and hazardous waste personnel include:

• Containment Buildings (covers the purpose and applicable operating standards)
• Tanks (covers key elements of the hazardous waste tank program)
• Petitions, Delistings, and Variances (most successful petitions seek to add an analytical method or to delist a waste from a particular facility)
• Solid Waste Programs (includes the EPA’s efforts in Industrial Solid Waste)

This is a guideline for the training needed by your facility’s hazardous waste personnel. Remember that the EPA does not specify duration of training for small generators; it is up to you to ensure that your employees receive adequate training to maintain compliance. Training your employees will give them the confidence to work with the sometimes complex RCRA hazardous waste rules and help ensure compliance. Keeping your employees safe, protecting the environment, and avoiding costly penalties will benefit your entire organization. Depending on your training needs and available resources, you may want to partner with a fully certified and experienced waste management provider to assist with training.