“Only our shipping guy handles hazardous waste, so he’s the only one who needs HWH training, right?” 

We hear this all the time. And it’s wrong in ways that get facilities cited during inspections. 

Yes, whoever signs manifests and coordinates with your hazardous waste hauler needs HWH training. But the regulations don’t stop there. 

HWH Training Isn’t Just for Shipping Personnel 

California’s Title 22 regulations are clear on this point. Under 22 CCR 66265.16, training is required for all facility personnel involved in hazardous waste management activities—not just the people who ship waste off-site. 

Think about your operation. Who’s actually interacting with hazardous waste? 

• The operator running a process that generates spent solvent 

• The technician draining used oil from equipment 

• The line worker tossing contaminated rags into a waste container 

• The maintenance employee disposing of expired chemicals 

• The warehouse staff managing satellite accumulation areas 

None of these people ship anything. But all of them are generating or handling hazardous waste as part of their jobs. Under state and federal regulations, they qualify as hazardous waste handlers—and they need training. 

Don’t Forget Supervisors 

Here’s another gap we see regularly: trained operators reporting to untrained supervisors. 

Supervisors who oversee employees involved in hazardous waste generation or handling need HWH training too. They’re responsible for ensuring procedures are followed correctly. They need to understand the regulatory requirements, recognize when something’s wrong, and know what proper compliance looks like. 

An untrained supervisor can’t effectively oversee trained employees—and regulators know it. 

What the Regulations Actually Say 

For Large Quantity Generators (LQGs), California requires that facility personnel complete a training program within six months of their date of employment, with annual refresher training thereafter (22 CCR 66265.16). The training must cover hazardous waste management procedures relevant to the positions in which employees work. 

Small Quantity Generators (SQGs) must ensure all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities (22 CCR 66262.16). 

Notice the language: “facility personnel involved in hazardous waste management activities” and “all employees” with waste handling responsibilities. Not “shipping personnel.” Not “the person who signs the manifest.” 

For complete regulatory details, visit the DTSC Hazardous Waste Generator Requirements page. 

Why This Matters 

Inadequate HWH training is one of the most frequently cited violations during inspections. It’s low-hanging fruit for regulators because it’s easy to verify: either the training records exist and cover the right people, or they don’t. 

Penalties can reach thousands of dollars per violation. And if improper handling leads to a spill, an exposure, or a disposal problem, you’re looking at much bigger consequences. 

The frustrating part? This is entirely preventable. It just requires thinking more broadly about who “handles” hazardous waste at your facility. 

A Quick Gut Check 

Run through these questions: 

1. Who at our facility is involved in processes that generate hazardous waste? 
2. Who physically handles, moves, or stores that waste—even temporarily? 
3. Who supervises those employees? 
4. Have all of those people received HWH training? 
5. Is that training current and documented? 

If your HWH training list only includes shipping personnel, you’ve probably got a gap. 

We Can Help 

Figuring out who needs HWH training requires looking at your actual operations—not just job titles. Our team works with facilities across manufacturing, metal finishing, warehousing, transportation, and other industries to identify everyone who qualifies as a hazardous waste handler and ensure they’re properly trained. 

If you’re not confident your training program covers the right people, let’s talk. A quick review now is far easier than explaining gaps to an inspector later. 

Contact us to schedule a training review | Learn more about our HWH Training programs