Frequent Questions

What RCRA training regulations apply to a person signing a hazardous waste manifest on behalf of a large quantity generator (LQG)?

There are no RCRA training requirements specific to the individual signing a hazardous waste manifest.  However, training requirements for hazardous waste generators are required by both RCRA Subtitle C and the Department of Transportation (DOT). 

LQGs are required to follow the personnel training requirements in Section 265.16. These requirements, among other things, ensure that facility personnel are able to respond effectively to emergencies.  EPA's requirements for preparing and signing uniform hazardous waste manifests are based on DOT regulations.  DOT requires that the person signing the manifest have "first hand knowledge" of the information listed on the manifest and the regulations that apply to the waste. The generator must certify that the materials are properly classified, described, packaged, marked and labeled, and in proper condition for transporting (Memo, Springer to Sherman; November 19, 2003, RCRA Online #14687). The generator certification is required by RCRA (Section 262.23(a)) and DOT.

The regulations referenced above are available online at www.ecfr.gov.

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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