Carrie Bettinger, CHMM, CSP
As a Certified Hazardous Materials Manager (CHMM) and a Certified Safety Professional (CSP) I often make recommendations to our General Industry clients in an effort to lift their game with dealing with hazardous waste. There are multiple layers of compliance issues related to hazardous waste handling, and, as with most regulations, a little education (TRAINING!!) goes a long way in understanding the game plan! The intention of this blog is to provide a brief discussion of the key regulations and their associated training requirements.
The U.S. Environmental Protection Agency (EPA) has very strict guidelines regarding the generation, transportation, treatment, storage and disposal of Hazardous Waste, which General Industry businesses (schools, colleges; hospitals; trucking/freight companies; manufacturer; laboratories; well, just about everyone) needs to know!
OSHA uses the term "general industry" to refer to all industries not included in agriculture, construction or maritime. General industries are regulated by OSHA's general industry standards, directives, and standard interpretations.
Give me an R! Give me a C! Give me an R! Give me an A! Whats that spell?! HAZARDOUS WASTE!
The Resource Conservation and Recovery Act (RCRA) appeared on the environmental scene in 1976 after Congress decided that people shouldnt be building homes on top of highly hazardous waste dumps or Farmer Joe shouldnt have a side business of burying industrial waste on the family farm. RCRA is a complex law with lots of parts and many industries are affected by its components. In addition to being complex, the text of the Act with all of its parts and sections is hard to follow. My primary technical focus tends to be on the Generators of Hazardous Waste (40 CFR Part 262). RCRA Training requirements for generators can be found in 40 CFR 262.34(a)(4) which conveniently (NOT) refers you to look at 40 CFR 265.16 on Personnel Training.
But the EPAs RCRA law is not the only player when it comes to the game of shipping hazardous waste off your site. The other major player is the Department of Transportation (DOT), and its Hazardous Materials shipping training requirements are found in 49 CFR Part 172, Subpart H. The International Air Transport Association (IATA) has rules for the air transport of hazardous materials (http://www.iata.org/) including training requirements.
To simplify, RCRA is all about Hazardous WASTE and the DOT and IATA rules kick in when youre dealing with hazardous MATERIALS, and guess what hazardous waste is? Thats right its hazardous materials in DOT and IATA eyes. For those who generate or ship Hazardous Waste, compliance for with EPA RCRA and DOT /IATA rules starts with required and effective training.
The Required Training
So, if you generate hazardous waste and you need to get it off your site, here is a brief summary of the training employees who either generate or handle hazardous waste should have -- per both EPA and DOT/IATA.
All employees at sites that generate hazardous waste need to be trained in how to:
- Properly identify what qualifies as regulated Hazardous Waste per federal (EPA) or your state requirements.
- Know where to properly dispose of any hazardous waste you may generate (I will give you a hint: Its NOT down the sink drain!).
- Know how to handle and dispose of highly hazardous waste (very toxic, reactive or explosive) to prevent injuries, and who to contact for questions or emergencies.
Employees who are designated as responsible for the management and control of this hazardous waste need additional training. And, depending on the size of the facility, it is prudent to provide this training to a backup employee or two. This additional training includes how to
- Properly label containers
- Implement accumulation area requirements and time-on-site limits
- Inspect hazardous waste accumulation areas for leaking or damaged containers or other problems
- Complete Hazardous Waste shipping manifests
- Ensure proper shipping methods and a qualified transporter are used
- Develop site-specific procedures
- Know and implement emergency procedures and site contingency plans
A common point of confusion is when refresher training is needed for employees. The DOT and EPA have two separate requirements:
- The EPA requires annual refresher training for their regulations.
- The DOT requires refresher training every 3 years for their regulations.
And, companies must ensure training for new employees or those newly assigned to the role within 6 months of their new post to be in compliance with both RCRA and DOT regulations.
The Bottom Line
We can all help to ensure clean air, clean soil and clean water in our neighborhoods by understanding and following federal and state hazardous waste/hazardous materials regulations. When accidents happen (and they do), labeling, manifests, emergency plans everything that DOT/IATA and RCRA training develops for your company are vital in the cleanup of the environment and protection of employee and public health and safety.
For more information or questions regarding how to handle hazardous waste or where to obtain training, please comment below or contact Emilcott. As part of The Emilcott Training Institute, we offer private hazardous communication, hazardous materials and hazardous waste training specific to company or site needs. We also offer public classes for both DOT/IATA and RCRA: