Frequent Questions

What RCRA training requirements apply to hazardous waste generators?

The amount and/or type of training required for hazardous waste generators is dependent on the amount of hazardous waste generated by the facility in a calendar month. According to 40 CFR Section 262.34(a)(4), generators who generate more than 1,000 kg/month of hazardous waste (or more than 1 kg/month of acutely hazardous waste)(LQG) must comply with the emergency preparedness and personnel training requirements in Section 265.16. Generators who generate greater than 100 kg but less than 1,000 kg/month of hazardous waste (SQG), must comply with the emergency preparedness and personnel training requirements in Section 262.34(d)(5). The training requirements do not apply to generators of less than 100 kg/month (e.g., conditionally exempt small quantity generators) or to personnel who work only in satellite accumulation areas. 

Additional guidance on the training requirements for hazardous waste generators is available in the following memos:
Memo, Springer to Sherman; November 19, 2003 (RCRA Online #14687)
Memo, Cotsworth to Tierney; June 10, 1997 (RCRA Online #14286) 
Memo, Denit to Bell; October 7, 1993 (RCRA Online #11779)
Memo, Lowrance to D'Aloia; May 9, 1989 (RCRA Online #11429)
Memo, Lowrance to Duprey; October 27, 1988 (RCRA Online #11373)

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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