Annual Training for Hazardous Waste Personnel
In This Article
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State Hazardous Waste Regulations
State regulations pertaining to hazardous waste may vary slightly from those presented here.  However, the fundamental requirements for training remain.  Be sure to check with your state.
United States
RCRA v. 40 CFR
RCRA, the Resource Conservation and Recovery Act is the legislation passed by Congress in 1976.  It was used as a foundation for the regulations drafted by USEPA beginning in 1980 and codified in Title 40 of the CFR, Parts 239-299.  While RCRA is the source, it is usually the regulations to which you refer in order to determine compliance.
  Follow this link to learn the who, what, where, and when, for the training, and to register if you're ready!
Can my Hazardous Waste Generator Status Change?
It can change month-to-month depending on the amount of hazardous waste you generate.  Usually, a company will comply with the most stringent regulations, i.e. those of a higher status, even if not always subject to them in order to ensure compliance.
Hazardous Waste v. Hazardous Materials
The USEPA defines a hazardous waste and requires training for personnel depending on the amount generated.
The USDOT defines a hazardous material (HazMat) to include a hazardous waste, and a lot more.  USDOT training is required for all HazMat Employees regardless of the amount of hazardous material the facility ships or receives.
Training and the Uniform Hazardous Waste Manifest
The RCRA Manifest is a document required by both the USEPA and the USDOT.  Therefore, a person who signs the Manifest may need Hazardous Waste Personnel training, depending on their hazardous generator status, but they must have HazMat Employee training.   More...
What is Required Before Training?
The USEPA allows for 180 days after new employment or job responsibility to train Hazardous Waste Personnel as long as the untrained person is directly supervised by trained and knowledgeable personnel in that time.
Follow this link to learn the who, what, where, and when, for the training, and to register if you're ready!
Other Training Services:
Onsite Training - I bring the training to your site.
Self-Guided Training - I'll provide you with the tools to conduct your own training.
Do you need this web-based training?
The US Environmental Protection Agency and your State environmental agency think so. 
Dear EHS Professional,
You may have several questions about the applicability of these regulations to your company.  If you're reading this, then it is likely that you are subject to the regulations of both the USEPA and your State for the generation and management of hazardous waste.   As such you, and perhaps several others at your company, must receive training of a type and at a frequency mandated by the regulations .

The purpose of this document is to answer your questions and to assist you in complying with Federal and State regulations.
Why a webinar?
I'll be the first to admit that there are limitations on the quality of the training you can provide via the internet.  However, it remains the best option available for those who lack the time and budget to travel to a Seminar and/or don't have enough employees to justify Onsite Training.

thoughtful-junkmail.jpg And this isn't your parent's webinar!  First of all: it's live, with an instructor (me) who will answer your questions and review complex information.  Trainees have several methods to communicate with me and are encouraged to do so; questions are always welcome and answered.

I do my best to keep the experience simple for you.  No software to download and no ads!  You just click on the link I provide, follow the instructions, and you're experiencing the webinar, both audio and video.
W Drums of Inks and Solventshat is a hazardous waste?
A waste is any solid, liquid, semi-solid, or contained gaseous material you discard, destroy, dispose of, recycle (yes, recycle), or store on-site in lieu of one of the previous four.
A hazardous waste is a waste that the USEPA believes poses substantial or potential threats to public health or the environment.  By definition it must include the following:
  • Not excluded by regulation (there are a lot of exclusions).
  • Listed by its source or its technical name at 40 CFR 261, Subpart D.
  • Exhibits any of the characteristics of hazardous waste at 40 CFR 261, Subpart C.

Listed hazardous waste includes:

  • Generated at a non-specific source, eg. spent organic solvents.
  • Generated at a specific source, eg. petroleum refining.
  • A commercial chemical product (eg. zinc cyanide, toluene) that is discarded, off-spec, container residues, or spill residues.

Characteristic hazardous waste exhibits one of the following:

  • Ignitability (commonly, but mistakenly, referred to as flammability).
  • Corrosivity
  • Reactivity
  • Toxicity
A subset of hazardous waste are acute hazardous wastes which have a higher level of regulatory responsibility.

All of the above (and more!) will be addressed during this RCRA Training Webinar.

Map of U.S. showing where Generator Improvements Rule in Effect What about the Generator Improvements Rule?
On May 30, 2017 the Generator Improvements Rule went into affect, making over 60 changes to federal regulations of the USEPA.  Changes to state regulations will take place over time and vary in their implementation as states select which changes to adopt and which to reject.  Read:  What is the status of the Generator Improvements Rule in my state?
Sooner or later you will need to comply with the requirements of this rule that are more strict than existing regulations (e.g. Changes to Hazardous Waste Labeling and Marking).  You can learn about all of them in this one webinar!

Close up Answering Question with Placard
Why Daniels Training Services?
What separates me from other training providers is that I understand the needs of business and don't spend time explaining things that won't help you to do your job.  My training is intensive, we cover a lot of information in 3 hours, but I enjoy what I do, and I believe that comes across in the training.  No one has ever complained of my Training Webinars being boring!  It has been my pleasure to bring new information and regulatory compliance to hundreds of people, and I hope I can do the same for you.
What is your hazardous waste generator status?
The amount of hazardous waste you generate will determine your hazardous waste generator status.  The three USEPA defined generator status are summarized as:
  • If you generate equal to or more than 1,000 kg (2,200 lb) of hazardous waste or more than 1 kg (2.2 lb) of acute hazardous waste per calendar month, you are a Large Quantity Generator (LQG).
  • If you generate more than 100 kg (220 lb) but less than 1,000 kg (2,200 lb) of hazardous waste per calendar month, you are a Small Quantity Generator (SQG).
  • If you generate equal to or less than 100 kg (220 lb) of hazardous waste and equal to or less than 1 kg (2.2 lb) of acute hazardous waste, you are a Very Small Quantity Generator (VSQG).

Your status may change if you exceed your on-site accumulation weight limit:

  • 1,000 kg (2,200 lb) for a VSQG.
  • 6,000 kg (13,228 lb) for an SQG.
  • There is no on-site accumulation weight limit for an LQG.

Your status may change from a generator to storage facility if you exceed your on-site accumulation time limit:

  • 90 days for an LQG.
  • 180 days for an SQG.
  • There is no on-site accumulation time limit for a VSQG.

This RCRA Training Webinar will address the regulatory requirements of all three hazardous waste generator status.

Advantages to a webinar:
  • Convenient - scheduled for business mornings.
  • Inexpensive - only $189/person.
  • Frequent - one RCRA Webinar/month.
  • Short - three hours and we're done.
  • Compliant - fulfills the requirements for Hazardous Waste Personnel training at 40 CFR 262.17(a)(7).
  • Easy - easy to register, easy to pay, easy to attend, easy to complete the necessary recordkeeping and receive your certificate.
  • Portable - anywhere you have an internet connection.
  • Low Tech - no software to download, no stringent technical requirements, it's a webinar for EHS Professionals, not IT.
  • Documented - I'll provide you with the form to document the training and a certificate of completion when it's all over.
Containers of Hazardous Waste
Training requirements for hazardous waste generators
Your hazardous waste generator status determines your training requirements (and a lot of other things) under the USEPA hazardous waste regulations:
  • A VSQG has no training requirement, though it is a good idea to have some familiarity with the regulations.
  • An SQG must ensure that all employees are "thoroughly familiar" with proper waste handling and emergency procedures relevant to their responsibilities.  Though not a formal requirement for training, it does establish a performance standard that can be met through high-quality training.  More...
  • An LQG must provide initial training (within 180 days) and a review of the initial training at least once per year for all facility personnel.  Training must include the facility's emergency procedures, teach facility personnel how to perform their duties in compliance with the regulations, and cover the requirements of the facility's contingency plan.  The training program must be directed by a person who has received training within the last year.  Therefore, if you intend to provide training for your personnel, you must receive some form of annual Hazardous Waste Personnel training.

My RCRA Training Webinar meets - and exceeds - all of these training requirements.

Will I receive a certificate from a Daniels Training Services webinar?
Yes you will.  This webinar meets the USEPA requirements at 40 CFR 262.17(a)(7) for both initial and annual training for Hazardous Waste Personnel.  The certificate of completion you are issued at the conclusion of the webinar documents this.

At the beginning of the webinar I assist you with completing the training record form I created to meet the specific requirements of 40 CFR 262.17(a)(7)(iv).  Upon completion of the RCRA Training Webinar I will email to you a certificate of completion including your name and the date the training took place.
Even if you aren't interested in my RCRA Training Webinar at this time, please don't h lounging-laptop-man.jpgesitate to contact me with any questions about the RCRA regulations or any of my other training options.


Daniel Stoehr
Daniels Training Services | 815.821.1550 | |
PO Box 1232
Freeport, IL 61032