MUCH OF THE SAFETY TRAINING provided by Safety Solutions & Supply is geared toward helping companies and their employees fulfill mandates handed down by the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) and/or Mining Safety and Health Administration (MSHA), and that includes hazardous waste training.
When it comes to training and support on matters of hazardous waste, though, SS&S instructors and consultants are working in territory regulated by the U.S. Environmental Protection Agency (EPA). The EPA was founded in December 1970. Less than six years later, in 1976, it was given the authority to develop and manage the now-vast provisions of The Resource Conservation and Recovery Act (RCRA), the principal federal law that governs the disposal of solid waste and hazardous waste. The RCRA also regulates the management of medical wastes and underground storage tanks.
According to the RCRA, a hazardous waste is a waste that either appears on one of three “lists” created by the EPA, or, if not on the lists, exhibits one of four “characteristics” of waste that would be considered hazardous ― ignitability, corrosivity, reactivity, and toxicity. The EPA’s lists of hazardous waste are wastes from non-specific sources, the “F” list; wastes from specific sources, the “K” list; and a list of discarded commercial chemical products, the “P/U” list.
Wastes the EPA classifies as hazardous (the number is large but difficult to pin down) can include the fairly simple and common ― used oil, chemical-soaked rags, spent solvents, pesticides, and manufacturing residues ― to the more complex ― electroplating byproducts, residues from manufacturing and wastewater treatment processes, wood preservers, organic and inorganic chemicals, petroleum refining byproducts, and unused but discarded commercial chemical products and their containers.
When it comes to this type of training, there’s a common misconception that it’s just for special emergency responders, those often referred to as “hazmat” (hazardous materials) or “hazwoper” (Hazardous Waste Operations and Emergency Response) personnel. On the contrary, facilities that manage hazardous waste of any kind and any quantity must comply with RCRA regulations, which frequently are subject to revision and expansion. Just recently, the EPA updated its RCRA-related regulations in more than 60 specific areas.
The RCRA mandates that employers train workers or have them trained (by certified providers such as Safety Solutions & Supply) on proper hazardous waste management and comply with stringent rules for hazardous waste generation, storage, treatment, and disposal.
The timetable and frequency for EPA-required RCRA training depends on a facility’s monthly hazardous waste volume ― or “generator status” and other factors. In the Code of Federal Regulations (CFR), the EPA has established three categories of hazardous waste generators:
- Large Quantity Generators (LQGs) ― those generating 2,200 pounds or more of regular hazardous waste monthly or those generating more than 2.2 pounds of acutely hazardous waste monthly.
- Small Quantity Generators (SQGs) ― those generating less than 2,200 pounds of regular hazardous waste monthly and generating 2.2 or fewer pounds of acutely hazardous waste monthly.
- Very Small Quantity Generators (VSQGs) ― those generating 220 or fewer pounds of regular dangerous waste monthly.
The RCRA requires that LQGs train “personnel” annually, with “personnel” being defined as “all persons that 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.” SQGs must ensure that all employees are “thoroughly familiar” with waste handling and emergency procedures relevant to their job responsibilities. VSQGs must use best-management practices to train their employees as often, and as long, as appropriate to ensure compliance with RCRA regulations.
Hazardous waste management is a serious responsibility for any business that falls under RCRA provisions, and having the knowledge to do it right is essential. Safety Solutions & Supply offers comprehensive solutions to ensure that relevant facilities comply with all RCRA regulations. From waste identification, packaging, and reporting to training, shipping, and ultimate disposal, Safety Solutions & Supply offers cost-effective RCRA training and consultation services.
SS&S instructors and consultants are ready now to ensure that waste-management teams are up to date on all the recent regulatory changes. To schedule training and on-site consultation related to waste-management programs and practices, call SS&S at 1-866-537-2262.