Do You Need to Take the RCRA Hazardous Waste Generator Course?
The RCRA Hazardous Waste Generator course is designed for anyone who deals with or manages hazardous waste. This can include but is not limited to waste generators, supervisors, environmental compliance professionals, and hazardous waste specialists.
The EPA has indicated that hazardous waste generator training is required for any individual who labels or moves hazardous waste containers, performs inspections or the functions of an emergency coordinator, or prepares, reviews, or signs hazardous waste manifests.
Training is required within 6 months of employment or assignment to a new position for both small quantity generators (SQG) and large quantity generators (LQG). Annual training is also required.
Why Choose NET for RCRA Hazardous Waste Generator Training?
Our RCRA Hazardous Waste Generator course is designed to let you complete your training at your own pace and on your own time. You can work from any device using HAZWOPER On Mobile, and start and stop the course as often as you wish while your progress is saved right where you left off.
Download your e-certificate immediately upon completion of the course. A wallet card will be mailed to you.
The RCRA Hazardous Waste Generator course counts as continuing education units (CEUs). This course is accepted for .50 Industrial Hygiene CM Points by the American Board of Industrial Hygiene (ABIH) and .3 Continuance of Certification (COC) points from the Board of Certified Safety Professionals (BCSP).
U.S.-based support is available throughout the course and an OSHA Study Timer tracks your completed time and allows you to log in and out as desired.
The RCRA Hazardous Waste Generator course includes a full-length video with over 20 interactive animations and award-winning content. Completion of the course involves navigating through self-grading quizzes and a final exam.
All completed hours count as CEUs (Continuing Education Units).
This RCRA training online has been awarded .5 Industrial Hygiene CM Points by the American Board of Industrial Hygiene (ABIH) — approval number 13337. This course is also eligible for .3 Continuance of Certification (COC) points from the Board of Certified Safety Professionals (BCSP).
Upon completion of the RCRA Hazardous Waste Generator course, students will have a thorough understanding of:
- When a waste is considered hazardous.
- Listed and Characteristic Hazardous Wastes
- The “Mixture Rule” and “Derived From Rule”
- Performing a Hazardous Waste Determination
- Which wastes are exempt from regulations
- The Empty Container Rule
- Categories of Hazardous Waste Generators
- Determining a Generator Status
- Rules for Satellite Accumulation Areas and Storage Areas
- Paperwork requirements for Land Disposal Agreements
- RCRA reporting and record keeping
- Used Oil requirements
- Universal Wastes
- Roles and responsibilities of the Emergency Coordinator
Physical and On Site Requirements
There are no prerequisites for the RCRA Hazardous Waste Generator course.
Who is required to take RCRA Training?
Under the RCRA regulations small quantity generators (SQG) and large quantity generators (LQG) of hazardous wastes are required to provide personnel with initial RCRA training within 6 months of employment or assignment to a new position with hazardous waste management tasks and annual RCRA training thereafter.
An SQG generates between 100 kilograms (220 lbs.) and 1,000 kilograms (2,200 lbs.) of non-acute hazardous waste and no more than 1 kilogram (2.2 lbs.) of acute hazardous waste per calendar month. An SQG can store hazardous waste for 180 days or less but the storage amount cannot exceed 6,000 kilograms (13,200 lbs.). RCRA training is required.
An LQG generates 1,000 kilograms (2,200 lbs.) or more of non-acute hazardous waste or more than 1 kilogram (2.2 lbs.) of acute hazardous waste per calendar month. An LQG can store hazardous waste for 90 days or less. For a LQG, all “facility personnel” are required to receive this training. Facility personnel are defined under 40 CFR 260.10 as “all persons who work at, or oversee the operations of, a hazardous waste facility, and whose actions or failure to act may result in noncompliance with the requirements of part 264 or 265”. Although this definition is vague, EPA has indicated in various guidance documents and memos, individuals who perform one or more of at least the following hazardous waste functions are required to receive hazardous waste training:
- Label hazardous waste containers;
- Move hazardous waste containers;
- Perform inspections;
- Perform the functions of an emergency coordinator; and
- Prepare, review, or sign hazardous waste manifests
How do RCRA and OSHA training overlap?
RCRA training and OSHA required HAZWOPER training can overlap. The U.S. EPA enforces protection of the environment regulations and OSHA enforces worker protection regulations.
There are many times these two sets or regulation overlap. Facilities that have the potential for an emergency to occur due to an uncontrolled release of hazardous substances or hazardous raw materials are required to provide training required under HAZWOPER 29 CFR 1910.120 paragraph (q). Employers who have hazardous waste storage areas must provide training required under either 29 CFR 1910.120 (p)(8) or (q) for those areas. However, both paragraphs provide exemptions from the basic requirements if the employer intends to evacuate all employees in the event of and emergency and call in a trained emergency response team. In this case employers must provide an emergency action plan and training in accordance with 29 CFR 1910.38(a). The training requirements of 29 CFR 1910.38 are minimal, requiring the training of a sufficient number of persons to assist in the safe and orderly evacuation of employees in the event of an emergency.
The basic requirements of OSHA HAZWOPER paragraph (q) include the provision that all employees who work in and are where there is a potential for an uncontrolled release must have sufficient awareness training to recognize that the emergency response situation exists and to initiate emergency response procedures. This “Awareness Level” training typically takes 4 hours to complete and includes training in the following areas: (A) An understanding of hazardous substances and the risks associated with a release. (B) An understanding of the potential outcomes associated with an emergency created when hazardous substances are present. (C)The ability to recognize and identify the presence of hazardous substances in an emergency.
What are the RCRA regulations?
The RCRA regulations establish a comprehensive hazardous waste management system under the authority of RCRA Subtitle C. RCRA regulates hazardous waste from its point of generation through its point of final disposal. Hazardous waste generators must undergo RCRA training and are the first link in the cradle-to-grave hazardous waste management system. Pursuant to the authority granted by RCRA §3002(a), EPA has developed generator standards that address on-site accumulation of hazardous waste, cradle-to-grave tracking (manifest system), labeling, and recordkeeping and reporting requirements. These standards are found in 40 CFR Part 262.
The RCRA sets forth an approach for handling the volumes of waste generated in the United States each year. Based on the authority granted by RCRA Subtitle C, EPA developed regulations for the cradle-to-grave management of hazardous waste. Persons who produce hazardous waste, called hazardous waste generators, are the first link in this cradle-to-grave system and they must receive RCRA training. The RCRA regulations establish basic hazardous waste management standards for generators.