Environmental Health and Safety Blog | EHSWire

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 Rules

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! What’s that spell?!  HAZARDOUS WASTE!

The Resource Conservation and Recovery Act (RCRA) appeared on the environmental scene in 1976 after Congress decided that people shouldn’t be building homes on top of highly hazardous waste dumps or Farmer Joe shouldn’t 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 EPA’s 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 you’re dealing with hazardous MATERIALS, and guess what hazardous waste is?  That’s right it’s 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:   It’s 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

Refresher Training

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:

• 4-hour Introduction to RCRA Compliance (40 CFR 260-273)


• 4-hour Introduction to DOT/IATA Compliance (49 CFR 172.704 & DGR 1.5.0)

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Topics: Emilcott, OSHA, DOT, General EHS, EPA, Emergency Response, H&S Training, Hazardous Waste Management, Hazardous Materials, Compliance, Lab Safety & Electrical, regulation, General Industry, emergency response training, Occupational Training, IATA, Resource Conservation and Recovery Act, Lab Safety, hazwaste, transportation, hazmat, generation, RCRA

Capt. John DeFillippo, CHMP, EMT-B

“Every day there are more than 800,000 shipments of hazardous materials (hazmat) in trucks-usually flammable liquids, such as gasoline, or flammable gas. About 200 hazmat trucks a year are involved in fatal crashes and 5,000 in nonfatal crashes. Although these numbers are small relative to the totals of almost 5,000 trucks involved in fatal crashes and 400,000 involved in nonfatal crashes annually, the potential for human injury and property damage in hazmat crashes is much greater.”

Ralph Craft, Ph.D.
Analysis Division, Office of Information Management, US Department of Transportation

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Topics: Emilcott, DOT, General Industry H&S, General EHS, H&S Training, Hazardous Waste Management, HazCom, Hazardous Materials, Compliance, Occupational Safety, regulation, Hazard Communication Standard, Public Safety, Lab Safety

Carrie Bettinger - CSP, CHMM

It’s a windy, rainy day in northern New Jersey today and, as I drive through my town, I see the sanitation trucks are out to collect garbage and paper recyclables as early as they can before everything is soaked.  My town roads are basically paved horse trails so imagine narrow, winding roads with lots of sharp curves with a posted speed limit of 25 MPH.  So why is one of the garbage trucks going about 35MPH on one of these roads with a soaking wet worker standing on the truck’s rear platform clinging with a death grip to the side?  Is it that important to get the garbage in as fast as possible?  Why is the worker not in the truck if they are not making stops?  Does one of these workers have to die before this sanitation company takes steps to stop these stupid and unsafe acts?

As an experienced Safety Professional, I’m trained to recognize compliance-driven and non-compliance "best practice" occupational safety violations.  However, what does it take to change laws and habits that affect workers and citizens?  In our society and legal system it seems that, yes, someone (or many) has to tragically die before change and regulation are considered.

Let’s review some of our history:

1911:  The Triangle Shirtwaist Factory Fire in New York resulted in 146 worker deaths due to locked escape routes leading to local then nationwide Life Safety Laws.

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Topics: OSHA, health and safety, General Industry H&S, General EHS, Construction H&S, Chemical Safety Board, Compliance, worker safety, Occupational Safety, Occupational Training, Lab Safety, Safety Training in Spanish, water safety

Capt. John DeFillippo, CHMP, EMT-B

These are tough economic times and businesses are looking to cut costs and save money. A disturbing trend I have noticed is the willingness of many companies to make cuts in safety programs and employee training in a misguided attempt to improve the bottom line.

Trained workers are safer workers.  The facts bear this out. Shortsighted statements I’ve heard include; “We don’t have problems in that area, so we’re cutting back on training.”, when the training was most likely the reason for the lack of problems.

Often, it is difficult to see how beneficial training can be until you experience the effects of its absence. Negative indications show themselves in higher EMRs, increased workman’s compensation claims, lost production time, and property damage. Only companies actively tracking and trending incidents are likely to realize this. (By the way, such companies would also be the ones least likely to make such cuts in the first place!)

It takes just one serious incident resulting in injuries to quickly eliminate any savings associated with cutting programs and training.  What’s more, most health and safety training is required by regulations, so there is also the risk of fines for non-compliance. These can be hefty and since most companies don’t budget for them, they become an extraordinary cost – right off the bottom line!

At Emilcott, we have seen firsthand the effects that result from a lack of training.  Recently, we were hired by a client who laid-off their safety director a couple years prior.  After starting our work, we informed the client of numerous safety violations throughout their organization. These appeared to be a direct result of the lapse in proper safety training – since they no longer had a safety director to oversee their program.  Through the Emilcott Training Institute, our client was able to receive the training needed to avoid these safety violations – and keep their employees safe and on the job. However, in their attempt to save money, the client ended up spending more in a short period of time just to catch up.

Making drastic H&S budget cuts just never pay off.  As experienced health and safety consultants, we work with our clients to offer solutions when budgets get tight:

• Outsource until you can hire again – we have provided EHS professionals at our clients’ sites for just this purpose for both short and long term requirements.


• Prioritize your H&S needs – consider the total reduction in your workforce or operations to determine where you can pull back and where you cannot.


• Take advantage of training courses open to the public – it may no longer be economically sound to run a training course in-house, but don’t lapse on required courses.


• Take advantage of FREE resources – many consultants provide lots of free info and OSHA will provide all types of assistance at no cost. As an example, Emicott offers a comprehensive Free Training Needs Assessment at www.emilcott.com!


• Pool resources – look toward your industry’s professional organizations or neighboring companies to share services. Maybe a part-time Safety Director is better than none at all.


• Ask a professional – put together a plan and a program to get you through the lean times

Has your company adjusted their health and safety program for leaner times?

Have you seen a direct effect and how are you compensating?

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Topics: OSHA, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Fire Safety, Occupational Training, Lab Safety, Safety Training in Spanish

EHS Top Ten Tuesday: Fire Safety

Eileen Lucier

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Topics: OSHA, health and safety, General Industry H&S, H&S Training, Hazardous Materials, Occupational Health, Occupational Safety, Fire Safety, Occupational Training, Lab Safety, Medical Records, NFPA

Topics: OSHA, Personal Protective Equipment, health and safety, General Industry H&S, Emergency Response, H&S Training, Hazardous Waste Management, Lab Safety & Electrical, Occupational Training, Lab Safety

Topics: OSHA, General Industry H&S, H&S Training, HazCom, Hazardous Materials, Lab Safety & Electrical, MSDS, Occupational Training, Lab Safety, hygiene standard