Any facility that generates hazardous waste during their operations is regulated under the Resource Conservation and Recovery Act (RCRA) of 1976, which is the principal federal law governing hazardous waste disposal in the United States. Because of this act, companies and organizations generating hazardous waste must be aware of their regulatory state and federal requirements. Employers often overlook crucial areas that involve the proper training of employees for safety during the handling of hazardous waste; however, in order to understand what training is required, you must be aware of the type of waste generator you are.

Small Quantity Generators Employee Training Requirements

The California Environmental Protection Agency (EPA) recognizes waste generators as either Small Quantity Generators (SQG’s) or Large Quantity Generators (LQG’s), requiring different employee training requirements for each. SQG’s must simply ensure that all employees have a thorough understanding of proper waste handling and emergency protocol, pertaining to their normal responsibilities during facility operations and emergencies.

Large Quantity Generator Training Requirements

The requirements for LQG’s are much more stringent, these requirements include:

The successful completion of a program of classroom instruction or on-site training that instructs employees on how to perform their duties in a way that ensures safety and compliance for the generator.

This training program must be directed by an experienced professional in hazardous waste management procedures and must include training that teaches employees those procedures; this includes ensuring that facility employees are able to quickly respond to emergencies by familiarizing them with emergency procedures and equipment.

New employees must successfully complete their training within six months after the start of employment or assignment to the facility. Employees must not work in unsupervised roles until they have completed the training requirements referenced above. They also must participate in a yearly review of the initial training.

In addition to the requirements, these documents must also be kept on-site:

1. A job title for each role that is related to hazardous waste management, as well as the names of the employees filling each job.
2. A written job description for each hazardous waste-related role, including the required education, skills, or other qualifications and duties of the employees filling each role.
3. A written description of the type of training and the amount that will be given to each employee.
4. Records documenting that the required training or job experience has been given to, and was completed by, facility personnel.
5. The training records of current employees must be kept until the site is closed. Generators are required to keep former employee training records for at least three years from the date the employee was last working on-site. Training records for employees being transferred within the same company can also be transferred to the site they will now be working at.

Complying with federal and state hazardous waste regulations can be complex and time consuming for many companies. A certified waste management company can be very useful by looking at current company practices like employee safety and training programs. Our experts at HTS can also help you look at ways to help reduce waste, helping you save time, money, and avoid regulatory fines. Our Environmental Health and Safety department is available for training and consulting year-round.