If You Don't Train Your Employees, You're Losing Money!

Posted by author Dawn DeVroom on Thu, Jun 20, 2013

If You Don't Train Your Employees, You're Losing Money!

Any business that generates hazardous waste as part of their operations is regulated under the Resource Conservation and Recovery Act (RCRA) of 1976. The RCRA is the principal the principal federal law that governs hazardous waste disposal in the United States.   It is crucial that businesses and organizations that generate hazardous waste as a part of their operations understand their regulatory requirements on both a federal and state level.   One very crucial
area that employers often overlook pertains to the proper training of employees for both safety and handling of hazardous waste. 

The first step to understanding your requirements is to understand what type of waste generator you are.


The California Environmental Protection Agency (EPA) identifies waste generators as either Large Quantity Generators (LQG’s) or Small Quantity Generators (SQG’s), and the employee training requirements are different for each.  SQG’s simply 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.



LQG’s have much more stringent requirements, including:

  • 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 generator's compliance with the regulatory requirements.
  • This program must be directed by a person trained in hazardous waste management procedures, and must include instruction that teaches personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed.
  • The training program must be designed to ensure that personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment and emergency systems, including other applicable requirements.
  • Personnel must successfully complete the program within six months after employment or assignment to the facility. Personnel must not work in unsupervised positions until they have completed the training requirements referenced above. They must also take part in an annual review of the initial training.

In addition to the training requirements the following documents must also be maintained:

  • The job title for each position related to hazardous waste management, and the name of the employee filling each job.
  • A written job description for each position related to hazardous waste management, including the required skill, education or other qualifications and duties of employees assigned to each position.
  • A written description of the type and amount of both introductory and continuing training that will be given to each person filling each of these positions.
  • Records that document that the training or job experience required has been given to, and completed by, facility personnel.
  • Training records on current personnel must be kept until closure of the site. Training records on former employees must be kept for at least three years from the date the employee last worked at the site. Personnel training records may accompany personnel transferred within the same company.

Maintaining compliance with federal and state hazardous waste statutes can be a complicated process for many companies.  A qualified waste management company can be of great help by looking at current procedures including employee safety and training programs. They can also help by looking at opportunities for Large Quantity Generators to minimize waste streams and change to Small Quantity Generator status.  This type of change can save time, money and minimize regulatory headaches.

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