RCRA training is one of the most important aspects of being compliant. And lack of it is also among the most frequent causes of citations for noncompliance. The requirements for RCRA training are often state-specific, and documentation and proper coverage are particularly important. Training also affects employees differently depending on their job role.
It’s particularly important to remember that training is there to ensure compliance. You can get cited for not having training, or not having records. But you can also get cited for employees not putting their training into action. The most common reason for an RCRA citation is mislabelling containers, which staff wouldn’t do if they were properly trained.
What is RCRA and what does it do?
RCRA is the Resource Conservation and Recovery Act, designed to give the EPA regulatory powers to prevent environmental damage from careless disposal of hazardous wastes. It grants the power to control how waste is stored, transported and disposed of.
RCRA creates cradle-to-grave liability for waste generators, meaning it’s still the responsibility of the entity that created it until it’s been safely disposed of in compliance with regulations. It also imposes training requirements on people who handle hazardous wastes.
There’s a guide to the provisions of RCRA here.
What is RCRA training?
- Ensure the facility is in compliance with RCRA requirements
- Be directed by a person trained in hazardous waste management techniques
- Be relevant to the work tasks and job roles of the employees being trained
‘Facility personnel must successfully complete a program of classroom instruction, online training (e.g., computer-based or electronic), or on-the-job training that teaches them to perform their duties in a way that ensures compliance with this part. The large quantity generator must ensure that this program includes all the elements described in the document required under paragraph (a)(7)(iv) [documentation requirements] of this section.’
It should cover ‘emergency procedures, emergency equipment, and emergency systems,’ such as:
- Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment;
- Key parameters for automatic waste feed cut-off systems;
- Communications or alarm systems;
- Response to fires or explosions;
- Response to ground-water contamination incidents; and
- Shutdown of operations.
Some states have their own agency with its own requirements, but by federal law these must be at least as stringent as those of the federal EPA, so these training requirements are a floor, not a ceiling.
Who needs RCRA training?
The type of training and the regulations that apply to personnel differ depending on your producer classification, job role, and location.
RCRA training requirements by waste generator status
Large Quantity Generators (LQGs)
LQGs generate over 1,000 kilograms of hazardous waste per month.
- Personnel must receive hazardous waste training within six months of being hired or assigned
- Personnel may not work unsupervised until their training is complete
- Training must be repeated annually
- Employers must keep records of hazardous waste training, including:
- Job titles and employee names related to hazardous waste management
- A written job description, which must include skills, education, qualifications and duties
- A written description of the type and amount of introductory and continuing training given to each person
- Records documenting completion of training and job experience requirements
- Records must be kept until the facility is closed. Former employee records must be kept for at least three years from employee termination, and personnel training records can follow staff transferred within the company
Small Quantity Generators (SQGs)
SQGs generate over 100 kilograms, but less than 1,000 kilograms of hazardous waste per month. If you generate over a kilogram of acutely hazardous waste, you’re automatically classified as an LQG.
‘The small quantity 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.’
Very Small Quantity Generators (VSQGs)
There are no federal requirements for VSQGs. However, there may be state-level regulations, and managers or owners of VSQGs can still benefit from employee training.
RCRA training by state
Most states have their own regulations, which often mirror federal rules closely but sometimes impose significant additional requirements.
In this table, links lead to the relevant state’s environmental regulations.
|Hazardous waste regulations||States and territories|
|Federal rules apply||Alaska, Iowa, federal tribal lands, American Samoa, the Northern Mariana Islands, US Virgin Islands, Puerto Rico|
|State rules and requirements are the same as federal rules||Idaho, Nevada, New York, North Carolina, Mississippi, Georgia, District of Columbia, Hawaii|
|State rules with minor variation from federal rules||Washington, Oregon, Montana, Wyoming, North Dakota, South Dakota, Nebraska, Utah, Colorado, Kansas, Missouri, Illinois, Wisconsin, Indiana, Ohio, Pennsylvania, New Jersey, New Hampshire, Massachusetts, Connecticut, Delaware, Kentucky, West Virginia,
Virginia, Tennessee, Arizona, New Mexico, Texas, Oklahoma, Arkansas, Louisiana, Alabama, South Carolina, Florida, Maryland
|State rules significantly stricter than federal regulations||California, Minnesota, Michigan, Rhode Island, Vermont, Maine|
States also sometimes determine waste generator status according to their own systems and nomenclature, so it’s important to know your state’s classification system and where your business fits into it.
What does RCRA training cover?
The EPA does not specify exact course requirements or training durations, only general training outcomes, meaning you have to decide on appropriate training within EPA guidance.
In particular, training modules should be selected that accord with job responsibilities, including:
- Identifying and characterizing RCRA wastes
- Scheduling waste shipments
- Performing accumulation area inspections
- Maintaining inventory logs
- Marking and labeling of containers
- Maintaining tanks
- Arranging hazardous waste shipments
- Assisting with routine compliance issues
- Managing residue containers
- Reporting releases of hazardous constituents
- Responding to releases
- Acting as an emergency coordinator
- Loading or transporting hazardous waste
The EPA provides information on the standards expected for training courses in areas including:
- Air Emission Standards
- Boilers and Industrial Furnaces
- Containment Buildings
- Corrective Action
- Definition of Solid Waste and Hazardous Waste Recycling
- Drip Pads
- Enforcement and Compliance
- Financial Assurance
- Groundwater Monitoring
- Hazardous Waste Identification
- Hazardous Waste Incinerators
- Land Disposal Restrictions
- Land Disposal Units
- Miscellaneous and Other Units
- Municipal Solid Waste Disposal Facility Criteria
- Other Laws that Interface with RCRA
- Permits and Interim Status
- Petitions, Delistings, and Variances
- Solid Waste Programs
- State Programs
- Statutory Overview
- Treatment, Storage, and Disposal Facility Criteria
- Used Oil
- Universal Waste
RCRA training requirements and curriculums vary from state to state. For example, New Hampshire requires that waste generators not only train all employees in accordance with federal RCRA requirements, but also designates federal LQGs and SQGs ‘Full Quantity Generators’ under state law. Such generators must have at least one on-site Hazardous Waste Co-ordinator, trained and certified by the New Hampshire Department of Environmental Services.
In Maryland, SQGs are subject to the same requirements as LQGs are under federal regulations, meaning additional training requirements. And Rhode Island has its own training curriculum, instructor qualification, and documentation requirements that are far more stringent than the EPA’s.
Where can you sign up for RCRA training?
Hazardous waste training has to be delivered by a person who is trained in hazardous waste management procedures. But the EPA does not have a trainer licensing program, or offer any accreditation. So there’s an open market in private training for RCRA. You can find RCRA training in your state by searching ‘[State] RCRA training.’
Here are five online options:
Priced at $99 per person, Hazwoper’s training is entirely online, device-agnostic and interactive, with the learner setting the pace. There’s a final exam with digital and hard copy certification, and online and phone support. The course covers:
RCRA HAZARDOUS WASTE GENERATOR: INTRODUCTION
Module 1: EPA Cradle-to-Grave Program
- Regulatory Overview
- Hazardous Waste – An Overview
- Hazardous Waste Generators
- Hazardous Waste Storage
- Hazardous Waste Transportation
Module 2: Regulations for Specific Wastes
- Managing Spills and Emergencies
- Regulations for Specific Wastes
- LDR, Recycling, and Used Oil
- Universal Waste
With a detailed discussion of waste management waste laws, Eduwhere’s course focuses more on a high-level understanding combined with detailed comprehension of the relevant legislation. It covers:
- Introduction to Hazardous Waste Management
- Hazardous Waste Determination
- Generator Status
- On-Site Management
- Record Keeping, Reporting, Spills, Training & Enforcement
- Off-Site Disposal, including 2006 Manifest Changes
- Used Oil, Universal Wastes and Mercury Containing Lamps
- Land Disposal Restrictions
Priced at $150 per person, the 5-hour course is taught by Department of Forestry and Environmental Technology at NC State University faculty member and is the former Director of Environmental Health & Safety at North Carolina State University’s IES Linda R. Taylor.
An 8-hour course for personnel involved in the shipping, handling, receiving and management of hazardous waste, HazmatCourse’s course involves:
- History of the RCRA Law
- Solid Waste, Hazardous Waste, and Recycling
- Summary of Regulations for Generators of Hazardous Waste and TSDFs
- Generator Regulations
- Transporter Requirements
- RCRA (Hazardous Waste Operations and Emergency Response)
- Incinerators, Boilers, and Industrial Furnaces
- RCRA Air Emission Standard
- TSD Facility Requirements
- Used Oil Management
- Land Disposal Restrictions
- Underground Storage Tanks
There’s a module-end quiz requiring a 70% score to proceed to the next module, and a final exam with a printable certificate. The course is priced at $99 per person and is particular to Pennsylvania: it’s included in this list to illustrate the necessity of finding a course that meets the requirements of your state, not just the federal requirements.
A refresher course for RCRA compliance that covers:
- Research Conservation Recovery Act (RCRA)
- Treatment, Storage, and Disposal Facilities (TSDFs)
- RCRA Requirements
A 100% online course with a printable certificate of completion, saveable progress and self-directed pace, the course is priced at $99 per person.
A Video-on-Demand based training course that covers:
- What is RCRA?
- Lists of Hazardous Wastes
- Characteristic Hazardous Wastes
- Employee Training
- Definitions of Small and Large Quantity Generators
- Satellite Accumulation Areas
- Safe Handling of Storage Containers
- Central Storage Area Requirements
- Treatment, Storage and Disposal Facilities (TDSF’s)
- The Uniform Hazardous Waste Manifest
- Information Contained in the Hazardous Waste Manifest
- Waste Minimization Procedures
With 13 lessons and 9 quiz questions, and downloadable resources, the course is expected to take about 30 minutes in total and is available in English and Spanish. It’s priced at $19.95.
Online courses vary widely in comprehensiveness and cost. In many cases, it’s better to find a directory of local suppliers and seek training providers that can facilitate an in-person training experience with direct, hands-on exercises.
What happens if you don’t get RCRA training?
Your employees could be improperly disposing of hazardous waste, leading to long-term environmental damage. More immediately concerning is the fine schedule for RCRA violations, raised in December 2020 to $76,764 per violation, per day — and that’s the civil penalty schedule. There’s also a criminal penalty schedule that includes maximum fines of $50,000 per violation per day and a prison term of up to two years. RCRA violations can add up quickly, and even very small generators are at risk in some states, so it makes sense to prepare by offering staff training.
The generator’s responsibility isn’t just from the generation to the proper disposal of the waste. It extends into their organization too, so training employees in best practices and compliant procedures is also up to waste generators. You’ll need to manage training, documentation, and renewal/review — and you’ll need to know your state-specific requirements too.