This webinar outlined the key requirements associated with RCRA training in an effort to help generators stay compliant and avoid expensive penalties. Attendees learned who should be RCRA trained and how much training is necessary, why training should be made a priority, and what the potential consequences are of falling short.

1. An Expert’s Guide to
RCRA Training
How Costly Impacts Can Be Avoided
with Hazardous Waste Training.

2. During this Webinar
All lines will be muted.
Communicate via the questions tab in your
webinar panel.
Unanswered questions will be personally after
the webinar.
Webinar recording and slides will be emailed to
you tomorrow.

3. Meet Your Presenter
Doug Graham, CHMM
Sr. EH&S Consultant &
External Training Manager
dgraham@triumvirate.com
22 Years training hazardous
waste generators in 12 states

4. Disclaimer
This webinar is not a RCRA training
course. Rather, it is a guide to
understanding the requirements around
RCRA training.

5. Our Key Message
RCRA Training Requirements are
Often State-Specific;
Documentation and proper coverage
is crucial to avoid what are common
violations

6. Who Is This For?
EH&S
Managers
Overall
Compliance
Employees with
Waste
Responsibilities
Individual
Compliance
Human
Resources
Training &
Recordkeeping

7. This Is Why
We’re Different
What
Others Say
Training is about “checking
the box”
RCRA training-
5 minutes and you’re
done… easy
It’s all the same stuff - the
trainer doesn’t matter
What We
Say Instead
Training is about
maintaining compliance
The requirements are
state-specific and affect
employees’ roles differently
Experience, perspective,
and the ability to engage
employees matter

8. OBJECTIVE
Learn who needs Hazardous
Waste (RCRA) training, including
how much, how often, what to
cover, and other regulatory
requirements

9. Key Takeaways
Applicable to employees who perform
hazardous waste-related tasks
Requirements vary by state and generator
status (size)
Required annually for some generators
Curriculum determined by tasks performed

10. Agenda
Training Overview: Who
Needs It and How Much?
Federal Training
Requirements
State Authorized RCRA
Programs
Potential Consequences of
Falling Short

11. Training in the. . .
U.S. Environmental Protection Agency (EPA) Hazardous
Waste Regulations (40 CFR 260-271)
And, if applicable, state-specific
hazardous waste regulations

12. Who are the facility personnel
who need training?
Those with RCRA-related job duties,
including:
• Identifying and characterizing wastes
• Completing waste information profiles
• Interacting with government officials
• Scheduling waste shipments
• Performing accumulation area inspections
• Performing hazardous waste tank inspections
• Maintaining inventory logs
• Recordkeeping
• Completing and/or signing manifests
• Completing annual/biennial reports

13. • Marking and labeling of containers
• Maintaining the main accumulation/storage area
• Maintaining tanks
• Maintaining satellite containers
• Arranging hazardous waste shipments
• Assisting with routine compliance issues
• Managing residue containers
• Reporting releases of hazardous constituents
• Responding to releases
• Acting as an emergency coordinator
• Loading or transporting hazardous waste
Those with RCRA-related job duties,
including:
Who are the facility personnel
who need training? (Cont’d)

14. Let’s Break it Down
Who? How Much?
How Often?
Curriculum? Instructor?
Recordkeeping?
By Generator Size: LQG,
SQG, CESQG

15. Agenda
Training Overview: Who
Needs It and How Much?
Federal Training
Requirements
State Authorized RCRA
Programs
Potential Consequences of
Falling Short

16. Federal Large Quantity Generator
(LQG) Training Requirements
40 CFR 265.16 (from 262.34(a)(4))
Key Regulatory Points (paraphrased):
265.16(a)(1)- Facility personnel must successfully complete a program of instruction
265.16(a)(2)- Directed by a person trained in hazardous waste management
265.16(a)(2)- Teaches procedures relevant to their job position
265.16(a)(3)- Must include emergency response procedures
265.16(a)(4)- HAZWOPER training may substitute for 265.16(a)(3)
265.16(b)- New employees trained within 6 months, and not unsupervised in the interim
265.16(c)- Annual review of the initial training (refresher)
265.16(d)-(e)- Training records
Applicable to “facility personnel” who perform hazardous
waste-related duties
LQG

17. Federal Training Requirements
40 CFR 265.16
LQG
“Successfully completed” implies the employer has
established a standard for success, (e.g.,
participation, involvement, testing, etc.). “ensures
the facility’s compliance” implies that the training
be performance-based. Style of training
(classroom, computer-based, hands-on) is flexible
(a)(1) Facility personnel must successfully complete a program
of classroom instruction or on-the-job training that teaches them
to perform their duties in a way that ensures the facility's
compliance with the requirements of this part. The owner or
operator must ensure that this program includes all the
elements described in the document required under paragraph
(d)(3) of this section.

18. Federal Training Requirements
40 CFR 265.16
LQG
(a)(2) This program must be directed by a person trained
in hazardous waste management procedures, and must
include instruction which teaches facility personnel hazardous
waste management procedures (including contingency plan
implementation) relevant to the positions in which they are
employed.
This clause establishes the qualifications of the
instructor being at a minimum a person who has
been trained themselves.

19. Federal Training Requirements
40 CFR 265.16
LQG
(a)(2) This program must be directed by a person trained in
hazardous waste management procedures, and must
include instruction which teaches facility personnel
hazardous waste management procedures (including
contingency plan implementation) relevant to the
positions in which they are employed.
This clause provides that training need only cover
those requirements that affect an employee’s
specific duties and that non-applicable topics need
not be covered.

20. Federal Training Requirements
40 CFR 265.16
LQG
(a)(3) At a minimum, the training program must be designed to ensure that
facility personnel are able to respond effectively to emergencies by
familiarizing them with emergency procedures, emergency equipment, and
emergency systems, including where applicable:
(i) Procedures for using, inspecting, repairing, and replacing facility emergency
and monitoring equipment;(ii) Key parameters for automatic waste feed cut-off
systems;(iii) Communications or alarm systems;(iv) Response to fires or
explosions;(v) Response to ground-water contamination incidents; and(vi)
Shutdown of operations.
This clause requires that RCRA training include
site-specific emergency response information, such
as the specifics of the facility’s contingency plan.

21. Federal Training Requirements
40 CFR 265.16
LQG
Because emergency response training is already
required under the OSHA HAZWOPER standard (29
CFR 1910.120(q)), that training will cover the
emergency-related topics required under RCRA.
(a)(4) For facility employees that receive emergency
response training pursuant to Occupational Safety and Health
Administration (OSHA) regulations 29 CFR 1910.120(p)(8)
and 1910.120(q), the facility is not required to provide
separate emergency response training pursuant to this
section, provided that the overall facility training meets all the
requirements of this section.

22. Federal Training Requirements
40 CFR 265.16
LQG
This establishes a 6-month window to get new
employees trained as long as they do not work
unsupervised during that pre-training period
(b) Facility personnel must successfully complete the program
required in paragraph (a) of this section within six months after the
effective date of these regulations or six months after the date of
their employment or assignment to a facility, or to a new position at
a facility, whichever is later. Employees hired after the effective date
of these regulations must not work in unsupervised positions until
they have completed the training requirements of paragraph (a) of
this section.

23. Federal Training Requirements
40 CFR 265.16
LQG
(c) Facility personnel must take part in an
annual review of the initial training required
in paragraph (a) of this section.
Refresher training is required annually.

24. Federal Training Requirements
40 CFR 265.16
LQG
(d) The owner or operator must maintain the following documents and
records at the facility:
(1) The job title for each position at the facility related to hazardous
waste management, and the name of the employee filling each job;
(2) A written job description for each position listed under paragraph
(d)(1) of this Section. 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 requisite skill,
education, or other qualifications, and duties of facility personnel
assigned to each position.
Training record must be maintained onsite and
include: name, job title, specific hazwaste duties,
requisite skill, education, or other qualifications.

25. Federal Training Requirements
40 CFR 265.16
LQG
(d)(3) A written description of the type and amount of both introductory and
continuing training that will be given to each person filling a position listed
under paragraph (d)(1) of this section;
(4) Records that document that the training or job experience required
under paragraphs (a), (b), and (c) of this section has been given to, and
completed by, facility personnel.(e) Training records on current personnel
must be kept until closure of the facility. Training records on former
employees must be kept for at least three years from the date the
employee last worked at the facility. Personnel training records may
accompany personnel transferred within the same company.
Additionally, a written description of type and
amount of training and documentation the training
was completed. The records for current employees
must be maintained until closure and for 3 years
beyond the date of last employment.

26. Federal Small Quantity Generator
(SQG) Training Requirements
262.34(d)(5)(iii)
SQG
(iii) The generator must ensure that all
employees are thoroughly familiar with proper
waste handling and emergency procedures,
relevant to their responsibilities during normal
facility operations and emergencies;

27. Federal Conditionally Exempt Small
Quantity Generator (CESQG) Training
Requirements
CESQG
There are no training requirements for
CESQGs on a federal level, however
employers are well advised to educate their
employees as to the applicable regulations

28. Agenda
Training Overview: Who
Needs It and How Much?
Federal Training
Requirements
State Authorized RCRA
Programs
Potential Consequences of
Falling Short

29. What About My State?

30. State Authorized RCRA Programs
State programs may adopt the federal training
requirements, or adopt more stringent
requirements

31. State Authorized RCRA Programs
Step 1: Determine your generator status as
defined by your state.
States may define generator status differently
than the EPA, sometimes even using different
names (e.g., “full quantity generator”, “fully-
regulated generator”, “SQG-Plus”, “VSQG”,
etc.)
The training requirements are often different
based on that state generator size
classification.

32. State Authorized RCRA Programs
Step 2: Read the specific training requirements in
the section of the state regulations addressing
your generator size classification.
Variations in the specific
training provisions in individual
state programs can be vastly
different.

33. State Authorized RCRA Programs
Some Regional Examples (East Coast)
• In New Hampshire, in addition to the training of employees, all Full
Quantity Generators (federal LQGs and SQGs) must have at least
one onsite “Hazardous Waste Coordinator” trained and certified by
the NHDES.
• In Rhode Island, the RIDEM mandates that LQGs and SQGs follow
very specific curriculum, documentation, and instructor qualification
provisions that far exceed the EPA’s.
• Maryland requires SQGs to also follow the federal LQG training
requirements (SQGs and LQGs are called “Fully-Regulated
Generators” in Maryland).

34. Agenda
Training Overview: Who
Needs It and How Much?
Federal Training
Requirements
State Authorized RCRA
Programs
Potential Consequences of
Falling Short

35. Potential Consequences
of Falling Short
Improper disposal resulting
in contamination of the
environment
Long-term liability
(potentially responsible
party status)
Civil penalties up to
$37,500 per violation, per
day (or more, in some
states)

36. Conclusion
It’s up to the generator to make sure all
affected employees are trained relative to their
responsibilities
AND to know their state-specific requirements.

37. Other Training Requirements
Other training requirements typical for EH&S professionals include:
• Emergency Response (HAZWOPER)
• DOT Hazardous Materials Training
• IATA Dangerous Goods Training (Air)
15 Separate OSHA Standards, including
• Hazardous Chemicals in Laboratories
• Control of Hazardous Energy (Lockout-Tagout)
• Confined Spaces
• Bloodborne Pathogens
• Electrical Safety
• Hazard Communication
• Access to Exposure and Medical Records
• Cranes
• Powered Industrial Trucks
• Portable Fire Extinguishers
• Employee Emergency Plans
• First Aid

38. QUESTIONS?

39. Thank You For Attending!
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