RCRA training requirements depend on the generator's status. LQGs must comply with the emergency preparedness and personnel training requirements in 40 CFR Section 265.16, which specify that facility personnel must take part in an annual review of their initial training. EPA expects companies to attempt to provide training so that personnel are trained every year. Training programs that allow as much as 15 months to pass between training courses, but ensure that employees, over the course of 4 years for example, receive 4 annual training reviews may meet the requirements.
SQGs must comply with the requirements in Section 262.34(d)(5). CESQGs are not required to comply with training requirements.
Hazardous waste transportation is regulated jointly under RCRA and DOT's hazardous materials regulations. Therefore, a generator who ships hazardous wastes off site would also need to comply with DOT's requirements for training hazardous materials employees in 49 CFR Part 172, Subpart H. The requirements include general awareness/familiarization, function-specific training, and safety training, The training must occur within 90 days of employment and must be repeated every 3 years.
References: 40 CFR Section 262.34(a)(4) and 262.34(d)(5)
Memo, Springer to Sherman, November 19, 2003 (RCRA Online #14687)
49 CFR Part 172, Subpart H
Memo, Cotsworth to Tierney, June 10, 1997 (RCRA Online #14286)
Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations including the designation of CESQG changing to very small quantity generator (VSQG). Other revisions may also 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.