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State regulations pertaining to hazardous waste may vary slightly from those presented here.  However, the fundamental requirements for training remain. Check with your state.

RCRA, the Resource Conservation and Recovery Act is the legislation passed by Congress in 1976.  It was used as a foundation for the regulations drafted by USEPA beginning in 1980 and codified in Title 40 of the CFR, Parts 239-299.  While RCRA is the source, it is usually the regulations to which you refer in order to determine compliance.

 

 

 

 

It can change month-to-month depending on the amount of hazardous waste you generate.  Usually, a company will comply with the most stringent regulations, ie. those of a higher status, even if not always subject to them in order to ensure compliance.

        

The USEPA defines a hazardous waste and requires training for personnel depending on the amount of hazardous waste a facility generates.

The USDOT defines a hazardous material (HazMat) to include a hazardous waste, and a lot more.  USDOT training is required for all HazMat Employees regardless of the amount of hazardous material the facility ships or receives.

Paints, resins, adhesives, cleaners, de-greasers, household products, hazardous wastes, solvents, aerosols, fireworks, batteries, mercury-containing devices, acids, bases, metal powders, pesticides & herbicides, inks, flavor concentrates, petroleum products, fuels, PCBs, asbestos, generators, welding gases...

The RCRA Manifest is a document required by both the USEPA and the USDOT.  Therefore, a person who signs the Manifest may need Hazardous Waste Personnel training, depending on their hazardous generator status, but they must have HazMat Employee training.

The USEPA allows for 180 days after new employment or job responsibility to train Hazardous Waste Personnel.  The USDOT allows only 90 days before training is required for HazMat Employees.  Both allow for this passage of time as long as the untrained person is directly supervised by trained and knowledgeable personnel.

There aren't any.  At least not any that apply to a shipper of a hazardous material.  There are some state regulations that apply to carriers (licensing, permits, etc.), but a shipper need only concern themselves with the Federal regulations of the USDOT found in Title 49 of the CFR, Parts 171-185.

 

 

 

 

Onsite Training - I bring the training to your site.

Web-Based Training - More convenience, less expense.

Self-Guided Training - I'll provide you with the tools to conduct your own training.

Do you need this training?

The US Environmental Protection Agency and US Department of Transportation think so. 

A waste is any solid, liquid, semi-solid, or contained gaseous material you discard, destroy, dispose of, recycle (yes, recycle), or store on-site in lieu of one of the previous four.

A hazardous waste is a waste that the USEPA believes poses substantial or potential threats to public health or the environment.  By definition it must include the following:

• Not excluded by regulation (there are a lot of exclusions).
• Listed by its source or its technical name at 40 CFR 261, Subpart D.
• Exhibits any of the characteristics of hazardous waste at 40 CFR 261, Subpart C.

Listed hazardous waste includes:

• Generated at a non-specific source, eg. spent organic solvents.
• Generated at a specific source, eg. petroleum refining.
• A commercial chemical product (eg. zinc cyanide, toluene) that is discarded, off-spec, container residues, or spill residues.

Characteristic hazardous waste exhibits one of the following:

• Ignitability (commonly, but mistakenly, referred to as flammability).
• Corrosivity
• Reactivity
• Toxicity

A subset of hazardous waste are acute hazardous wastes which have a higher level of regulatory responsibility.

The amount of hazardous waste you generate will determine your hazardous waste generator status.  The three USEPA defined generator status are summarized as:

• If you generate equal to or more than 1,000 kg (2,200 lb) of hazardous waste or more than 1 kg (2.2 lb) of acute hazardous waste per calendar month, you are a Large Quantity Generator (LQG).
• If you generate more than 100 kg (220 lb) but less than 1,000 kg (2,200 lb) of hazardous waste per calendar month, you are a Small Quantity Generator (SQG).
• If you generate equal to or less than 100 kg (220 lb) of hazardous waste and equal to or less than 1 kg (2.2 lb) of acute hazardous waste, you are a Conditionally Exempt Small Quantity Generator (CESQG).

Your status may change if you exceed your on-site accumulation weight limit:

• 1,000 kg (2,200 lb) for a CESQG.
• 6,000 kg (13,228 lb) for an SQG.
• There is no on-site accumulation weight limit for an LQG.

Your status may change from a generator to storage facility if you exceed your on-site accumulation time limit:

• 90 days for an LQG.
• 180 days for an SQG.
• There is no on-site accumulation time limit for a CESQG.

Your hazardous waste generator status determines your training requirements (and a lot of other things) under the USEPA hazardous waste regulations:

• A CESQG has no training requirement, though it is a good idea to have some familiarity with the regulations.
• An SQG must ensure that all employees are "thoroughly familiar" with proper waste handling and emergency procedures relevant to their responsibilities.  Though not a formal requirement for training, it does establish a performance standard that can be met through high-quality training.  More...
• An LQG must provide initial training (within 180 days) and a review of the initial training at least once per year for all facility personnel.  Training must include the facility's emergency procedures, teach facility personnel how to perform their duties in compliance with the regulations, and cover the requirements of the facility's contingency plan.  The training program must be directed by a person who has received training within the last year.  Therefore, if you intend to provide training for your personnel, you must receive some form of annual Hazardous Waste Personnel training.

A hazardous material (HazMat) is anything the USDOT has determined poses an unreasonable risk to health, safety, and property when transported in commerce.  It includes the following:

• A material whose technical name is listed in the hazardous materials table, eg. Acetone or Hydrochloric acid.
• A material that meets the definition of a hazard class or division:
• Class 1 Explosive
• Class 2 Compressed gases
• Class 3 Flammable and combustible liquids
• Class 4 Flammable and reactive solids
• Class 5 Oxidizers and organic peroxides
• Class 6 Poisons and infectious substances
• Class 7 Radioactive
• Class 8 Corrosive
• Class 9 Miscellaneous
• A hazardous substance, eg. 1 lb of Sodium nitrate.
• A hazardous waste.
• A marine pollutant, eg. copper metal powder.
• An elevated temperature material, eg. Sulfur, molten.

As defined by the USDOT, a HazMat Employee is any person whose job duties have a direct effect on the safe transportation of a hazardous material.  HazMat Employee job duties include:

• The loading and unloading of hazardous materials by Shipping and Receiving personnel.  This includes the bulk transfer to or from a tank truck to/from a storage tank.
• The design, testing, marking, certification, manufacturing, re-conditioning, etc. of a HazMat packaging.
• The preparation of a HazMat for transportation, including pre-transportation functions:
• Classifying the hazardous material.
• Selecting, filling, and closing the HazMat packaging.
• Applying labels and markings to the HazMat package.
• Preparing shipping papers, eg. preparing, reviewing, or signing the Uniform Hazardous Waste Manifest.
• Providing emergency response information to the carrier.
• Those responsible for purchasing raw materials.
• Laboratory personnel.
• The operation of a motor vehicle transporting hazardous material over a public roadway.
• The supervision of a HazMat Employee who performs any of the above.

Those that employ HazMat Employees (aka. a HazMat Employer) must provide initial training (within 90 days) and full training at least once every three years thereafter.  Training content must include the following:

• General Awareness/Familiarization
• Function Specific Responsibilities
• Safety/Emergency Response
• Security General Awareness
• In-Depth Security Training (if subject to the regulations).

The regulations require that HazMat Employees be tested to demonstrate their knowledge of the regulations as part of the training.

Their is no training or certification requirement for the trainer, however, this places a heavier burden of responsibility on the HazMat Employer as it is they, and not the trainer, that must ensure the training and testing is adequate.  So, make certain that whomever you choose for your HazMat Employee trainer, they know the Hazardous Material Regulations and how to present them.

What separates me from other training providers is that I understand the needs of business and don't spend time explaining things that won't help you to do your job.  My training is intensive, we cover a lot of information in 8 hours, but I enjoy what I do, and I believe that comes across in the training.  No one has ever complained of my training being boring!  It has been my pleasure to bring new information and helpful tools to hundreds of people, and I hope I can do the same for you.

Yes.  The certificate, along with the training materials themselves, are the only documentation required to certify that you have been trained (and tested for HazMat Employees) per the requirements of the applicable regulations.  The HazMat Employee certificate requires the signature of the HazMat Employer in addition to mine as the training provider.

Even if you aren't interested in my training seminar at this time, please don't hesitate to contact me about any of my other training options, or if you have any questions about the transportation of hazardous materials or the management of hazardous waste.

Daniel Stoehr