What is RCRA Hazardous Waste Training?
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Who must Receive RCRA Hazardous Waste Training?
Under the Resource Conservation and Recovery Act (RCRA) regulations small quantity generators (SQG) and large quantity generators (LQG) of hazardous wastes are required to provide personnel with initial training within 6 months of employment or assignment to a new position with hazardous waste management tasks and annual training there after.
A SQG generates between 100 kilograms (220 lbs.) and 1,000 kilograms (2,200 lbs.) of non-acute hazardous waste and no more than 1-kilogram (2.2 lbs.) of acute hazardous waste per calendar month. A SQG can store hazardous waste for 180 days or less but the storage amount cannot exceed 6,000 kilograms (13,200 lbs.).
A LQG generates 1,000 kilograms (2,200 lbs.) or more of non-acute hazardous waste or more than 1 kilogram (2.2 lbs.) of acute hazardous waste per calendar month. A LQG can store hazardous waste for 90 days or less. For a LQG, all "facility personnel" are required to receive this training. Facility personnel are defined under 40 CFR 260.10 as "all persons who work at, or oversee the operations of, a hazardous waste facility, and whose actions or failure to act may result in noncompliance with the requirements of part 264 or 265".
Although this definition is vague, EPA has indicated in various guidance documents and memos, individuals who perform one or more of at least the following hazardous waste functions are required to receive hazardous waste training:
• Label hazardous waste containers;
• Move hazardous waste containers;
• Perform inspections;
• Perform the functions of an emergency coordinator; and
• Prepare, review, or sign hazardous waste manifests.