Training consistently ranks high on lists of most frequently cited RCRA violations. View this presentation to understand the key requirements associated with RCRA training to stay compliant and avoid expensive penalties.

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 responded to in the next couple
of days.
 Webinar recording and slides will be emailed to you tomorrow..

3. Meet Your Presenter
Doug Graham, CHMM
EH&S Practice Director –
Training Services
Triumvirate Environmental
24 years training hazardous
waste generators in 13 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 are 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, VSQG

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 262.17(a)(7)
Key Regulatory Points (paraphrased):
262.17(a)(7)(i)(A)- Facility personnel must successfully complete a program of instruction
262.17(a)(7)(i)(B)- Directed by a person trained in hazardous waste management
262.17(a)(7)(i)(B)- Teaches procedures relevant to their job position
262.17(a)(7)(i)(C)- Must include emergency response procedures
262.17(a)(7)(i)(D)- HAZWOPER training may substitute for 262.17(a)(7)(i)(C)
262.17(a)(7)(ii)- New employees trained within 6 months, and not unsupervised in the interim
262.17(a)(7)(iii)- Annual review of the initial training (refresher)
262.17(a)(7)(iv)- Training records
Applicable to “facility personnel” who perform hazardous
waste-related duties
LQG

17. Federal Training Requirements
40 CFR 262.17
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)(7)(i)(A) Facility personnel must successfully complete a
program of classroom instruction, online training (e.g.,
computer-based or electronic), or on-the-job training that
teaches them to perform their duties in a way that ensures
compliance with this part. The large quantity generator must
ensure that this program includes all the elements described in
the document required under paragraph (a)(7)(iv) of this
section.

18. Federal Training Requirements
40 CFR 262.17
LQG
(a)(7)(i)(B) 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 262.17
LQG
(a)(7)(i)(B) 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 262.17
LQG
(a)(7)(i)(C) 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 262.17
LQG
Because emergency response training is already
required under the OSHA HAZWOPER standard (29
CFR 1910.120), that training will cover the emergency-
related topics required under RCRA.
(a)(7)(i)(D) 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 262.17
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
(a)(7)(i) 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 262.17
LQG
(a)(7)(iii) 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 262.17
LQG
(a)(7)(iv) The owner or operator must maintain the following documents
and records at the facility:
(A) The job title for each position at the facility related to hazardous
waste management, and the name of the employee filling each job;
(B) A written job description for each position listed under paragraph
(a)(7)(iv)(A) 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 262.17
LQG
(a)(7)(iv) . . .
(C) 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;
(D) Records that document that the training or job experience required
under paragraphs (i), (ii), and (iii) 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
40 CFR 262.16(b)(9)(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 Very Small Quantity Generator
(VSQG) Training Requirements
formerly known as Conditionally Exempt Small Quantity Generators (CESQGs)
VSQG
There are no training requirements for VSQGs
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. Federal RCRA Program States
Alaska and Iowa are the only states that are
federal RCRA programs administered by EPA.

31. Federal RCRA Program Territories
EPA administers RCRA programs in Federal tribes,
American Somoa, the Northern Mariana Islands, and the
U.S. Virgin Islands. Puerto Rico also follows the federal
rules although not administered by EPA.

32. State RCRA Program States Incorporating
EPA Rules by Reference
New Jersey and Pennsylvania incorporate the federal rules
by reference, so like Alaska, Iowa, and the territories, the
EPA Generator Improvements Rule changes have already
gone into effect.

33. Other State Authorized RCRA Programs
Other state programs however, may incorporate
the federal training requirements, or adopt more
stringent ones.

34. 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.

35. 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.

36. 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).

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

38. Potential Consequences
of Falling Short
Improper disposal resulting in
contamination of the environment
Long-term liability (potentially responsible
party status)
EPA Civil penalties up to $70,117.00 per
violation, per day (individual states may vary)

39. 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.

40. 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

41. QUESTIONS?

42. Thank You For
Attending!
• You will receive an email tomorrow with a
copy of this presentation and recording
• Please complete our short survey
• Register for an upcoming training near you:
http://www.triumvirate.com/training/open-
enrollment-training
Contact:
Doug Graham, CHMM
dgraham@triumvirate.com