Frequent Questions

What documentation must a generator maintain to demonstrate compliance with the RCRA training requirements (40 CFR §265.16)?

A generator must maintain training-related documents and records at the facility (§265.17(d)). The records must include: 

  • a job title for each position at the facility related to hazardous waste and the name of the employee filling that position (§265.16(d)(1)); 
  • a written job description for each position at the facility related to hazardous waste (§265.16(d)(2)); 
  • a written description of the type and amount of both introductory and continuing training that will be given to each person filling such a position (§265.16(d)(3)); and
  • records that document that the training or job experience required has been given to, and completed by, facility personnel (§265.16(d)(4)). 

The generator must maintain training records on current personnel until closure of the facility and former employees for three years (§265.16(e)). 

Additional clarification is available in the following guidance document: 
Monthly Call Center Report Question; December 1984 (RCRA Online 12341

The guidance document referenced above is available in the RCRA Online database at the following URL: 
https://yosemite.epa.gov/osw/rcra.nsf/how+to+use?OpenForm

Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations. These revisions may affect the information provided in this FAQ. The final rule and additional information, including a fact sheet, frequent questions, and a webinar recording and slides, are available at www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements.

The Hazardous Waste Generator Improvements Final Rule is effective on May 30, 2017; however, implementation in a particular state depends on the state’s authorization status. A discussion of the effect that this final rule will have on state authorization is available on page 85801 of the rule. Information about how the rule will affect the requirements in this FAQ in a particular state is best obtained from the state hazardous waste program. A list of state hazardous waste programs is available at www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies.

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