/     IN THIS BLOG

Hazardous waste generators face significant training needs no matter their size. Regardless of how much or how little hazardous material an organization generates, personnel must be able to act in accordance with state and federal regulations. Most notably, these include regulations from the Occupational Safety and Health Administration as well as the Resource Conservation and Recovery Act (RCRA). These federal regulations require employers to train certain personnel to comply with stringent safety storage, treatment, and disposal requirements when dealing with hazardous wastes. Failure to provide required training can result in civil penalties of up to $80,000 per day per violation. The specific training requirements these employers face depend upon their category of generator. Here, we will take a closer look at these training requirements and who they apply to.

01   /  Very Small Generators

Very Small Quantity Generators (VSQGs) include facilities that generate 100 kilograms or fewer of hazardous waste each month or one or fewer kilograms of acutely hazardous waste. These generators face the fewest requirements of the three categories outlined in the RCRA.

The three most important requirements these VSQGs face are:

R
Identifying all hazardous waste generated.
R
Preventing accumulation of more than 1,000 kilograms of hazardous waste.
R
Ensuring the hazardous waste is transported to an authorized person or facility for further management.

02   /   What Are the Training Requirements?

Unlike larger waste generators, VSQGs are not required to receive training under RCRA to meet these requirements. However, it is strongly advised to receive basic training on RCRA in order to ensure compliance with its requirements.

OSHA provides an exemption from a great deal of its training requirements if the VSQG accumulates hazardous waste for less than 90 days. However, they still must develop an emergency action plan or an emergency response plan in order to be compliant.

MCF Environmental Services provides training to familiarize organizations with safe handling and storage practices. This training is designed to help organizations audit their facilities for OSHA compliance as well as build safety plans to ensure they are ready for emergencies.

Very small generators are often businesses or organizations with extremely few employees. That means that while there are fewer people to train, it is more crucial to ensure everyone working with hazardous materials in any capacity is familiar with compliant handling and disposal processes. Also, smaller facilities cannot staff train en masse like larger facilities.

However, none of these factors have to obstruct very small waste generators. These smaller businesses and organizations can rely on training modules and educational resources from a waste management partner like MCF. Training to learn what very small waste generators must do to remain compliant with the waste they handle comes with the service MCF provides.

03   /   Small Quantity Generators

Small Quantity Generators (SQGs) include facilities that generate more than 100 but less than 1,000 kilograms of hazardous waste per month. Some major requirements faced by these facilities include:
R
Not accumulating hazardous waste for greater than 180 days unless by permit;
R
Preventing the accumulation of greater than 6,000 kilograms of hazardous waste.
R
Complying with hazardous waste manifest and pre-transport requirements;
R
Managing hazardous waste in appropriate containers in compliance with federal requirements;
R
Complying with preparedness and prevention requirements;
R
Submitting a biennial hazardous waste report; and
R
Ensuring a minimum of one employee is prepared and capable of acting as the emergency coordinator in the event of an emergency.
In addition to these requirements, the EPA also requires SQGs to confirm their SQG status every two years by submitting an updated 8700-12 form. This system is designed to help businesses ensure they are categorizing themselves correctly.

04   /   What Are the Training Requirements?

Under federal requirements, SQGs must ensure all “hazardous waste personnel” are “thoroughly familiar” with waste handling and emergency response procedures. Elements of emergency response training should include:
R
Details of the emergency response plan;
R
Procedures in the event of an emergency;
R
Key personal protective equipment;
R
And identifying potential hazards.
Under 40 CFR § 260.10, “Personnel or facility personnel means 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 of this chapter.”

What this means is that many employees who are not directly responsible for handling hazardous waste, but may play some role in compliance with RCRA requirements, may require training. At the very least, employees should be familiar with proper waste handling, emergency response, and any training related to their own job responsibilities.

Small waste generators face several more restrictions than very small generators, so it is equally, if not more, important for them to ensure all relevant staff are aware of the regulations affecting their work. Employees of small waste generators need training not just to meet minimum requirements per federal regulation but also to be knowledgeable about proper hazardous waste handling so they can ensure their work remains compliant. 

In order to provide the required training and to guarantee employees know what is demanded of them when handling hazardous waste, businesses and organizations should partner with a waste management service like MCF. This will ensure all relevant information for local and federal regulations are understood. MCF also provides applicable training materials for staff to refer back to after they’ve familiarized themselves with the requirements during training.

05   /   Large Quantity Generators

Large Quantity Generators (LQGs) include facilities that generate greater than 1,000 kilograms of hazardous waste or greater than 1 kilogram of acutely hazardous waste per month. Due to the large quantity of hazardous waste these facilities generate, they face stringent requirements, including:
R
Only accumulating waste for 90 days with limited exceptions;
R
Ensuring hazardous waste is contained in appropriate containers, drip pads, or buildings;
R
Complying with hazardous waste manifest and pre-transport requirements;
R
Complying with preparedness and prevention requirements; and
R
Submitting a biennial hazardous waste report.

06   /   What Are the Training Requirements?

In order to comply with these requirements, LGQs are required to provide hazardous waste personnel with specialized training within six months of beginning work. Until employees receive this training, they may not work unsupervised.

Training must include emergency response training similar to small quantity generators; however, in addition, they must meet additional training requirements. This includes:

R
How to perform their duties in a compliant manner;
R
How to inspect and maintain monitoring and emergency equipment;
R
Relevant communication and alarm systems;
R
Procedures for responding to fire, explosion, or groundwater contamination; and
R
How to shutdown operations.
Facilities must maintain records of training for all current personnel and for at least three years after the last date of their employment. In addition, annual refresher training is required for all personnel.

Large quantity generators often have many employees–consequently, they have a greater amount of staff who need to be trained in compliant handling. As a result of their size, they also face more risks for noncompliance (and consequent fines) and are more closely regulated. 

Outsourcing many aspects of hazardous waste management, including offering staff relevant training, to an experienced waste management partner can help larger companies reduce the burden of hazardous waste handling. MCF offers training resources applicable to large quantity generators detailing federal regulations and expectations as well as information on local and state requirements.

07   /   Compliance

All generators, regardless of size, must remain mindful of compliance. Avoiding noncompliance and fines for improper handling or disposal begins with a knowledgeable and well-trained staff. All companies and organizations that create regulated forms of waste should take numerous precautions, including:
R
Staying ahead of federal regulations through frequent, up-to-date training
R
Determining their waste generation size (a waste management partner can help with this)
R
Establishing clear plans and strategies for all aspects of handling hazardous materials
R
Sharing the waste management strategy throughout the facilities
R
Partnering with an experienced waste disposal company for training and general assistance

08   /   Proper Training Saves Time & Resources

Hazardous waste generators face many training requirements to ensure safe operations and preparedness in the event of an emergency. These requirements increase proportionally to the size of the facility, and a failure to meet them can add up quickly should the government pursue the maximum $80,000 daily penalty for each violation. However, no matter the size, training is crucial to ensure not only compliance but the safety of employees and the public at large. Reach out to the hazardous waste experts at MCF Environmental Services to learn more about the best way to train your staff.

Robert Losurdo

President, COO

Categories

Archives