RCRA Hazardous Waste Training Requirements
RCRA Demo
RCRA Hazardous Waste Training Requirements
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© 2013 Lion Technology Inc., Lafayette, NJ 07848 1/28/13
RCRA Demo
RCRA HAZARDOUS WASTE TRAINING REQUIREMENTS
RCRA Hazardous Waste Training Requirements
© 2013 Lion Technology Inc.
EPA’s Hazardous Waste Rules • Specific set of rules for storing, moving, treating, and disposing of materials that are “defined” as hazardous waste • Variety of storage options for hazardous wastes: – Satellite accumulation – 180-day accumulation – 90-day accumulation – Universal waste accumulation © 2013 Lion Technology Inc.
Three Types of Hazardous Waste Generators • There are three types of generators regulated under the hazardous waste rules 1. Conditionally exempt small quantity generators 2. Small quantity generators 3. Large quantity generators • Type of generator determines the storage rules you are allowed to follow
© 2013 Lion Technology Inc.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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RCRA Demo
RCRA Hazardous Waste Training Requirements, continued
Conditionally Exempt Small Quantity Generators • Generate < 100 kg (220 lbs) per month hazardous waste • Accumulate < 1,000 kg (2,200 lbs) on-site • Not required to follow any of the on-site storage options BUT: – Still required to follow rules for conditionally exempt small quantity generators – Training not required but would be a good management practice [40 CFR 261.5] © 2013 Lion Technology Inc.
Small Quantity Generators • Generate between 100 and 1,000 kg (220 and 2,200 lbs) per month hazardous waste • May follow any of the on-site storage options
[40 CFR 260.10] © 2013 Lion Technology Inc.
Large Quantity Generators • Generate > 1,000 kg (2,200 lbs) per month hazardous waste • May follow any of the on-site storage options EXCEPT for the 180 day rules
[40 CFR 262.34(a)] © 2013 Lion Technology Inc.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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RCRA Demo
RCRA Hazardous Waste Training Requirements, continued
Satellite Accumulation Satellite accumulation occurs when employees accumulate hazardous waste: • At or near the point of generation RCRA Waste Training • Where theHazardous waste initially accumulates Requirements • Without complying with the 180-day or 90-day regulations
[40 CFR 262.34(c)] © 2013 Lion Technology Inc.
Training Requirements for Employees EPA’s Hazardous Waste Rules Working in Satellite Accumulation Areas Specific set requirements of rules for storing, • No specific in the moving, hazardous treating, and disposing of satellite materialsemployees that are waste regulations to train “defined” as hazardous waste • Employers must still make certain that each • Variety of storage options for hazardous employee doing accumulation under this wastes: option knows his or her responsibilities in – Satellite accumulation order to avoid noncompliance with rules – 180-day accumulation – Training would be a good – 90-day accumulation management practice – Universal waste accumulation © 2013 Lion Technology Inc.
Training Three Requirements Types of Hazardous for Employees Waste Working in Satellite Generators Accumulation Areas Employees • There are who threework types in of satellite generators areasregulated BUT also under move thehazardous hazardouswaste wasteinto rules 180 or 90 day storage areas are subject to small training 1. Conditionally exempt quantity requirements for employees working in these generators areas 2. Small quantity generators 3. Large quantity generators • Type of generator determines the storage rules you are allowed to follow
© 2013 Lion Technology Inc.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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RCRA Demo
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180-Day Accumulation • Rules allow small quantity generators to accumulate waste “anywhere” on site (i.e., other than the point of generation) • Waste can Hazardous be held for up to 180 days RCRA Waste Training Requirements – In most states can hold for up to 270 days if shipping further than 200 miles • Can accumulate a maximum of 6,000 kg of waste on-site (including satellite areas) [40 CFR 262.34(d)] © 2013 Lion Technology Inc.
180-Day Accumulation Area Training EPA’s Hazardous Waste Rules Requirements •Employees Specific set of rules for storing,familiar” moving,with must be “thoroughly treating, and disposing of materials that are waste handling and emergency procedures. “defined” as hazardous waste • Variety of storage options for hazardous wastes: – Satellite accumulation – 180-day accumulation – 90-day accumulation – Universal waste accumulation [40 CFR 262.34(d)(5)(iii)] © 2013 Lion Technology Inc.
Three Types of Hazardous Waste 180-Day Accumulation Area Training Topics Generators • There aretopics three types of generators regulated No specific required to be covered undertraining the hazardous waste rules during Conditionally small • 1. Train employees exempt how to do theirquantity jobs and generators what they need to do during emergencies 2. Small quantity generators 3. Large quantity generators • Type of generator determines the storage rules you are allowed to follow
© 2013 Lion Technology Inc.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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RCRA Demo
RCRA Hazardous Waste Training Requirements, continued
Training Frequency for Employees in 180-Day Areas No specific requirements to retrain • If job functions change, rules change, or as time passes and employees begin to forget training, they will no longer be “thoroughly familiar” with proper procedures • As good management practice, employees should be periodically retrained at whatever interval is determined to be appropriate
© 2013 Lion Technology Inc.
Training Documentation for Employees in 180-Day Areas No specific requirements to document training • As good management practice, training should be documented in such a manner as to be able to demonstrate that the required training was provided
© 2013 Lion Technology Inc.
90-Day Accumulation • Rules allow large or small quantity generators to accumulate waste “anywhere” on site (i.e., other than the point of generation) • Waste can be held for up to 90 days • No limit to the amount of waste that can be accumulated on-site under 90-day option
[40 CFR 262.34(a)] © 2013 Lion Technology Inc.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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90-Day Accumulation Training Requirements 90-day generators required to follow the same training standard that interim status treatment, storage, and disposal facilities (TSDFs) follow at 40 CFR 265.16
[40 CFR 262.34(a)(4)] © 2013 Lion Technology Inc.
90-Day Accumulation Training Requirements • Must provide all “personnel” with training regarding job-specific waste management procedures relevant to their positions – “Personnel” basically means anyone who could cause noncompliance with the hazardous waste regulations • Training must be directed by someone who has comprehensive training in hazardous waste management procedures [40 CFR 265.16(a)(1) and (2)] © 2013 Lion Technology Inc.
Specific Training Topics for Employees in 90-Day Areas Training must cover (as applicable to each person’s job responsibilities) the following: • Use, inspection, repair of emergency and monitoring equipment • Automatic waste feed cut-off systems • Communications and alarm systems • Response to fires or explosions • Response to groundwater contamination incidents • Shutdown of operations © 2013 Lion Technology Inc.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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RCRA Demo
RCRA Hazardous Waste Training Requirements, continued
Timing of Training for Employees in 90-Day Areas • Employees must receive initial training within six months of becoming personnel – Until trained, must be supervised • Employees must receive “annual” retraining
[40 CFR 265.16(b) and (c)] © 2013 Lion Technology Inc.
What Does “Annual” Training Mean? • U.S. EPA states “annual” means “annual” – Not explicitly required to retrain by anniversary date or every calendar year – Training should generally be within 12 months or so from previous training date • States operating own RCRA programs may explicitly require training to be provided once every calendar year or by the anniversary date of the previous training © 2013 Lion Technology Inc.
Training Documentation for Employees in 90-Day Areas Must create a written training plan that includes: • The job title for each position at the facility related to hazardous waste management • A written job description for each position listed above • The name of the employee filling each job • A written description of the type and amount of introductory and continuing training • Documentation that the required training or job experience has been given to and completed by facility personnel [40 CFR 265.16(d)] © 2013 Lion Technology Inc.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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Training Documentation for Employees in 90-Day Areas Training records must be kept: • Until closure for all current personnel • For at least three years from the date the employee last worked at the facility for former personnel
[40 CFR 265.16(e)] © 2013 Lion Technology Inc.
Universal Wastes Rules • Universal wastes are hazardous waste that are subject to alternative management requirements • Under Federal rules, universal wastes include the following: – Batteries – Lamps – Pesticides – Mercury-containing equipment • States may have different types of wastes as universal wastes [40 CFR 273] © 2013 Lion Technology Inc.
Training Requirements for Employees Handling Universal Waste • Employees that handle universal waste need to be trained regarding: – Proper handling procedures – Emergency procedures • Training should be appropriate for universal wastes at facility • No specific requirements to create training records or conduct periodic retraining – Good management practices [40 CFR 273.16 and 273.36] © 2013 Lion Technology Inc.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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RCRA Demo
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Hazmat Training Options • Public workshops in over 60 U.S. cities • 24/7 online courses flexible and effective • On-site training tailored to your materials View all courses: www.Lion.com/WasteCoursesCourses or call 888-546-6511
© 2013 Lion Technology Inc.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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RCRA Demo
RCRA DEMO
References
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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RCRA Demo
Training Requirements for Hazardous Waste Employees, continued
TRAINING REQUIREMENTS FOR HAZARDOUS WASTE EMPLOYEES
180-Day Training Requirements [40 CFR 262.34(d)(5)(iii)]
familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable:
(iii) 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.
(i) Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; (ii) Key parameters for automatic waste feed cut-off systems; (iii) Communications or alarm systems; (iv) Response to fires or explosions;
90-Day Training Requirements [40 CFR 265.16]
(v) Response to ground-water contamination incidents; and (vi) Shutdown of operations.
§265.16 Personnel training. Editor’s Note: §262.34(a)(4) requires that generators who are accumulating hazardous waste also comply with §265.16. (a)(1) Facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility’s compliance with the requirements of this part. The owner or operator must ensure that this program includes all the elements described in the document required under paragraph (d)(3) of this section. (2) This program must be directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. (3) At a minimum, the training program must be designed to ensure that facility personnel are able to respond effectively to emergencies by
(4) For facility employees that receive emergency response training pursuant to Occupational Safety and Health Administration (OSHA) regulations 29 CFR 1910.120(p)(8) and 1910.120(q), the facility is not required to provide separate emergency response training pursuant to this section, provided that the overall facility training meets all the requirements of this section. (b) Facility personnel must successfully complete the program required in paragraph (a) of this section within six months after the effective date of these regulations or six months after the date of their employment or assignment to a facility, or to a new position at a facility, whichever is later. Employees hired after the effective date of these regulations must not work in unsupervised positions until they have completed the training requirements of paragraph (a) of this section. (c) Facility personnel must take part in an annual review of the initial training required in paragraph (a) of this section. (d) The owner or operator must maintain the following documents and records at the facility:
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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RCRA Demo
Training Requirements for Hazardous Waste Employees, continued (1) The job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job; (2) A written job description for each position listed under paragraph (d)(1) of this Section. This description may be consistent in its degree of specificity with descriptions for other similar positions in the same company location or bargaining unit, but must include the requisite skill, education, or other qualifications, and duties of facility personnel assigned to each position;
(e) Training records on current personnel must be kept until closure of the facility. Training records on former employees must be kept for at least three years from the date the employee last worked at the facility. Personnel training records may accompany personnel transferred within the same company. [Source Note: At 71 FR 16908, April 4, 2006, effective May 4, 2006, added (a)(4). At 71 FR 40274, July 14, 2006, amended (b).]
(3) A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position listed under paragraph (d)(1) of this section; (4) Records that document that the training or job experience required under paragraphs (a), (b), and (c) of this section has been given to, and completed by, facility personnel.
© 2013 Lion Technology Inc., Lafayette, NJ 07848
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