If your facility is a large quantity generator (LQG), training is required for all facility personnel (40 CFR §262.34(a)(4), §265.16).
Personnel, or facility personnel are defined as 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 (§260.10). In addition, personnel may include contractors since contractors working at a TSDF are held to the same standards as non-contract facility personnel.
Additional clarification on the definition of facility personnel is available in the following guidance document:
Monthly Call Center Report Question; March 1998 (RCRA Online #14180)
In contrast, if your facility is a small quantity generator, the generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies (§262.34(d)(5)(iii)).
The guidance document provided above is available in RCRA Online at the following URL: https://rcrapublic.epa.gov/rcraonline
This guidance represents clarification of the Federal regulations. Since most states are authorized to implement the Federal regulations, you should contact your state agency for information on applicable training requirements for LQG facility personnel. State web sites may be found at the following URL: www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies
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.