Any business that generates hazardous waste as part of its operations is regulated under the Resource Conservation and Recovery Act (RCRA) of 1976.
One very crucial area that employers often overlook pertains to the proper training of employees for both safety and handling of hazardous waste. While training employees can be a financial investment, the alternative can be more costly. If untrained employees improperly dispose of hazardous waste, your company can face steep federal and state fines, along with a tarnished reputation.
Not sure where to begin? Here are some of the employee training requirements required of hazardous waste generators, along with one of the best sources of help to ensure your company remains compliant.
The first step to understanding your requirements is to know what type of hazardous waste generator you are. The U.S. Environmental Protection Agency divides waste generators into three main classifications based upon the quantity of hazardous waste generators produce:
In California, however, the Department of Toxic Substances Control divides generators into two categories:
As you can see, both the EPA and state of California have similar regulations in place as far as defining the amount of hazardous waste an entity produces per calendar month. However, it’s important to note that California does not have a conditional exemption for small quantity generators that generate 100 kilograms or less of hazardous waste.
It is critical to know what type of generator your company is because the employee training requirements are different for each. Very small quantity generators are exempt from any RCRA training requirements.
Small Quantitiy Generators or SQG’s 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.
However, the law does not specify how an employer must ensure all employees are familiar with waste handling and emergency procedures. Some options include prior work experience, training classes, on-the-job experience and signs that effectively communicate this information.
In contrast to small quantity generators, large quantity generators have much more stringent requirements, including:
In addition to the training requirements the following documents must also be maintained:
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.
An experienced hazardous waste transporter 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.
In fact, one of our clients experienced this exact scenario. The client came to us classified as a large hazardous waste generator, and after looking at the company and the waste that they generated, we realized the company was in fact misclassified and was actually a small waste generator.
This classification mistake on the company’s part resulted in wasted money spent to meet more stringent large generator requirements. On the other end, a company classifying itself as a small hazardous waste generator, when in fact is a large generator, could face steep fines for not meeting the appropriate hazardous waste generator regulations.
When looking for a hazardous waste disposal company to partner with, make sure it is licensed and registered in the state’s Registered Hazardous Waste Transporter Database. The best disposal companies will also offer a hazardous waste walk-through program.
A walk-through is an evaluation of your hazardous waste procedures. An experienced and properly licensed hazardous waste company should perform the walk-through to ensure that your hazardous waste procedures meet all state and federal regulations. This include the training portion of those requirements.
The process is collaborative and ensures your company and employees are protected, trained and in legal compliance. It’s important to note that in many cases, a walk-through will identify outdated training procedures that were once legal but have been changed over the years and are no longer valid.
Our article, The Benefits Of A Hazardous Waste Walk-Through, outlines some additional reasons why this service can benefit your company so that you can rest assured any compliance issues are caught early and training procedures you have in place are effective and according to the law.