RCRA (or the Resource Conservation and Recovery Act) training is required for businesses that handle hazardous waste or hazardous material (HAZMAT). The RCRA is a set of federal regulations overseen by the Environmental Protection Agency (EPA) that provides guidelines for the management of hazardous waste.
What is RCRA Training?
RCRA training is designed to educate employees on dealing with hazardous waste while minimizing the risk of exposure to workers and the environment. RCRA was a law passed in 1976 that gave the EPA the power to enforce guidelines regarding the management of hazardous waste.
It’s training covers topics relating to the management and safety procedures for hazardous waste. It should be carried out to ensure that employees know how to:
- Identify hazardous waste
- Properly label hazardous waste
- Properly store hazardous waste
- Conduct proper emergency response
- Prevent spills and conduct cleanups of hazardous waste
- Use personal protective equipment (PPE) properly
However, it doesn’t end with this general knowledge. Employees are obligated to train their staff on how to deal with the specific or unique hazardous waste management system for each facility where employees have to work and handle hazardous waste.
When and How Often is RCRA Training Required?
The frequency of RCRA training depends on the classification of the business or facility in terms of waste generation. There are three categories: namely, 1. Large Quantity Generators (or LQGs); 2. Small Quantity Generators (SQGs); 3. Very Small Quantity Generators (VSQGs); and 4. TSDDFs — treatment, storage, and disposal facilities.
The size classification is based on the amount of waste that is generated. The table below provides the basis of the classification.
| Classification | Acronym | Definition |
| Large Quantity Generator | LQG | 1000 kg of waste generated per month |
| Small Quantity Generator | SQG | More than 100 kg and less than 1000 kg of waste generated per month |
| Very Small Quantity Generator | VSQG | 1000 kg of waste generated per month |
Table showing the definition of waste generators according to size.
LQGs and TSDFs tend to have stricter requirements for training workers under RCRA. However, it is recommended that SQCs and VSQGs follow similar requirements as them. Let’s take a quick look at each category.
– Large Quantity Generators
Personnel involved in hazardous waste management at LQGs are required to obtain training within the first six months of being employed or assigned to a facility. Additionally, as an employer, you must ensure that they have yearly refresher training to keep them current on RCRA standards and regulations.
– Small and Very Small Quantity Generators
If you own an SQG or VSQG, there is no specific training frequency for your employees. However, you are responsible for ensuring that they are familiar with procedures to properly handle waste under both normal operations and in emergencies. Each employee should know what their role is based on their given responsibilities. Despite the lack of specific training frequency, it would be best to follow a schedule similar to LQGs.
– Treatment, Storage, and Disposal Facilities
The training requirements and scheduling for TSDFs are similar to those for LQGs. Initial training should be completed within six months of employment or assignment to a new facility, and yearly refresher training is also required.
What are the RCRA Hazardous Waste Training Requirements?
RCRA hazardous waste training requirements depend on the manner in which the waste is being handled. This can be divided into three categories. We will take a look at the training requirements for each category.
Requirements for Waste Generators
The training requirements for “waste generators” also depend on their size. LQGs have stricter training requirements. However, as with training scheduling and timing, it is recommended that SQGs and VSQs follow similar guidelines.
- LQGs. According to the EPA, for LQGs, “hazardous waste personnel” includes any employee or staff member whose actions may lead to noncompliance with relevant regulations for RCRA. This includes a long list of employees engaged in handling waste containers through the following actions:
– Selecting waste containers
– Marking waste containers
– Labeling waste containers
– Inspecting waste containers
– Moving waste containers
You should also note that this includes all staff, even if their role or job description on paper does not label or identify them as hazardous waste handlers. Any staff member who incidentally deals with hazardous waste should be adequately trained.
This training is not restricted to the staff members working for your organization. They also extend to include 1.) outside contractors hired to assist your company in managing hazardous waste on-site and 2.) any other contractors who in the course of work might produce waste on your site such as repair contractors, painters, or renovators.
- Small and very-small generators. The EPA requires that personnel working for VSQGs and SQGs to be “thoroughly familiar” with procedures for properly handling waste in daily or normal operations and emergency response situations.
Requirements for waste transporters
Federal training requirements for the transportation of hazardous waste or Hazmat transporters are complicated as they fall under three different agencies — the EPA, OSHA, and the DOT.
It would be difficult for the leadership or management of a small or even large organization to be fully aware of all these rules and regulations. Also, bear in mind that these regulations do not remain the same. They are being constantly updated. Therefore, to make sure that your business remains compliant, think of hiring expertise — such as what we provide here at CDMS.
Nonetheless, here is a list of basic training that employees handling hazardous waste must have:
- Security awareness training to know the security risks associated with hazardous waste transportation and specific strategies to reduce such risks.
- Function-specific training that aligns with the particular knowledge and skills necessary for an employee to carry out hazard waste transport duties responsibly and safely.
- Safety training for those who handle hazardous waste before, during, and after it is transported. This includes drivers, lifters, warehouse workers, and so on.
- Specialized driver training for i.) Inspecting and operating vehicles; ii.) Handlin vehicles in diverse conditions; and iii.) Familiarity with special rules.
- Advanced security training for employers or companies that are required to have a mandatory security plan to manage hazardous waste.
- Hazardous waste operations and emergency response (HAZWOPER) certification for relevant employees. This includes workers who have to:
- Drive vehicles into hazardous waste sites
- Enter treatment, storage, and disposal facilities that are EPA-regulated
- Serve as the first line of response to hazardous waste-related emergencies
Requirements for Waste Treatment, Storage, and Disposal
The RCRA mandates that all employees in your establishment and related facilities have the relevant certification. Such certification should allow them to perform duties in a way that ensures your business remains EHS compliant regarding hazardous waste disposal.
Businesses require annual certifications for the following:
- Refresher training on 1. making the distinction between solid waste and hazardous waste, 2. understanding waste codes and land ban requirements; 3. Identifying your generator status; 4. container requirements; workplace onsite standards; and 5. Recordkeeping
- Differentiating the various wastes. Workers should know the difference between universal waste, waste oils, electronic waste, and metal waste. They should also know various updated requirements for relevant treatments and disposal.
- Training on legal requirements. All relevant employees who handle hazardous waste should be trained on updates regarding RCRA enforcement trends, and the latest RCRA mandates and recommendations regarding due diligence and liberty.
What are the RCRA Hazardous Waste Lists?
Hazardous wastes can be categorized into four main categories:
- Flammable
- Reactive
- Corrosive
- Toxic
These four categories are further divided into four specific lists — F, K, P, and U. Each category is outlined in detail by RCRA to ensure that hazardous waste is disposed of and handled safely.
The table below describes each category:
| List | Description | Examples |
| F List | Hazardous solid wastes are from specific industrial processes that occur in various industries. They are called “non-specific source wastes.” |
|
| K List | These are solid hazardous wastes from 13 specific industries. |
|
| P List | This includes acute commercial chemical hazardous chemicals that are unused but that are thought of as hazardous upon being discarded. |
|
| U List | This includes toxic commercial chemical products that are unused but that are thought of as hazardous upon being discarded. |
|
California-Specific Rules
For RCRA, California-based businesses have to follow Federal requirements in addition to California-specific rules for Cal EPA. These are called “Non-RCRA / California-only hazardous wastes.”
They include:
- An M List of hazardous substances that contain mercury
- Some toxics and corrosives at levels below the federal minimum
- Common items like paint, motor oil, e-waste, etc.
These are regulated under Title 22 of the CCR and are subject to constant changes in regulation. So, you should keep an eye on them.
Conclusion
RCRA training and certification is a requirement for all companies handling or dealing with hazardous waste. There are a myriad of laws and rules to follow, including the EPA, Cal EPA, and other state laws regarding certification.
In California, there is a specific requirement for certification — namely, 24 contact hours of every two years. The list of hazardous wastes in California also differs slightly from federal lists and can be more stringent.
CDMS has the expertise and qualifications to provide such training for businesses based in California. Take a look at the services we provide for certification and training: Check out Hazard Waste Training from CDMS.
