Frequent Questions

When are the owners and operators of treatment, storage and disposal facilities (TSDF) required to conduct personnel training for employees? How often do facility personnel need to be trained?

Facility personnel at permitted and interim status TSDFs are required to complete a facility personnel training program within six months of their date of employment or assignment to a facility (§§264.16(b) and 265.16(b)). In addition, facility personnel must take part in an annual review of the initial training (§§264.16(c) and 265.16(c)). While it may be infeasible for companies with many employees to train each employee exactly one year after the last training, EPA expects companies to attempt to provide training so that personnel are trained every year (Memo, Cotsworth to Tierney; June 10, 1997 (RO 14286)). Large quantity generators (LQG) are also required to comply with the personnel training requirements in §265.16 (§262.34(a)(4)). 

Additional guidance regarding the personnel training requirements is available in the following documents:
Monthly Hotline Report Question; March 1998 (RCRA Online # 14180
Memo, Denit to Bell; October 7, 1993 (RCRA Online # 11779
Monthly Hotline Report Question; June 1984 (RCRA Online # 12245)

These documents are available at the following URL: 
www.epa.gov/rcraonline

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