Hazardous waste training is mandated by the Resource Conservation and Recovery Act (RCRA) under the authority of the EPA. If your facility generates any hazardous waste, to comply with the law, the act requires that employees who handle the waste be adequately trained. Given the immense consequences at stake—environmental, health and safety, financial, legal, and ethical—the responsibility of proper hazardous waste training for employees should be a top priority for facilities that generate hazardous waste.
By law, those employees handling hazardous wastes must complete a training program either through classroom instruction, computer-based online training, or through direct on-the-job training. All activity must be directed by a person trained in hazardous waste management procedures. The program must teach them to perform their duties in such a way as to ensure the facility complies. At a minimum, the training curriculum must ensure that facility personnel are capable of responding effectively to emergencies. They must be familiarized with emergency procedures, equipment, and systems.
To ensure that your personnel is well prepared to deal with an emergency, training staff should focus on several areas, including:
Site Specific Training
The RCRA regulations cover a wide variety of topics in hazardous waste training. Training regulations not only vary depending on the size and quantity of the monthly hazardous waste generated at a facility but on state laws and regulations, too. Some states may have more exacting requirements than federal law mandates. To meet all necessary regulations, ensure that personnel is trained to comply with the laws specific to your site’s location.
How To Respond To Emergencies
Emergency response is at the core of hazardous waste training, as responding to an emergency could be the difference between life and death. Because every hazardous waste generator is required by law to formulate an emergency contingency plan, as part of training, employees must have a thorough and detailed understanding of the plan and an actionable response to an emergency. Training would include procedures to minimize hazards and reduce risks to human health and the environment during the emergency. Personnel should have contact information and emergency phone numbers on hand, emergency equipment readily available, and additional emergency procedures related to the specific properties of the hazardous waste generated at the facility.
Training in Handling, Storage, and Disposal
Staff training in storing and handling hazardous waste generated at your facility should be at the core of their curriculum. Employees that work for hazardous waste generators must be thoroughly and adequately trained in handling and storing waste. In addition to covering all the various types and classifications of hazardous waste, the specific type of hazardous waste generated at your site, its properties, and associated risks is a topic that should be covered at length. However, several general issues need to be covered as well. Training should instruct employees in identifying hazardous wastes, selecting the correct storage container, where they should be located, knowing how to separate chemicals to prevent a reaction properly, and the procedures for transporting waste to a disposal site, among other topics.
Labeling Procedures and Protocols
Proper labeling is one of the many essential steps to safely handle, store, and ship hazardous waste. Therefore, knowing how to label hazardous waste properly is an integral part of training. To ultimately dispose of hazardous waste, generators must comply with EPA regulations and meet DOT (Department of Transportation) requirements for shipping. In addition, personnel must also be familiar with any state and local agency labeling requirements.
In training, employees must know how to correctly prepare a label and learn best practices for its placement on containers. Note that among the primary purposes of brands is to inform potential handlers of the hazardous risks of the material and ensure that incompatible materials are not stored or transported together. Hazardous waste label requirements can vary from state to state. In general, they include such information as the date when the accumulation of hazardous waste began, the type of material, its composition and current physical state, and the generator’s name and address. The label should visually indicate the primary hazard, as well.
Training is Ongoing
By law, RCRA hazardous waste regulations require annual training for designated hazardous waste personnel. However, ongoing training should be part of every program, as much because federal and state laws continue to change, as a way to stay on top of procedures and protocols to effectively manage hazardous waste at your facility. Managers should meet with staff to go over new laws and regulations and how they impact your facility whenever they are enacted. Establishing regular hazardous walk-through programs can help keep procedures and protocols fresh or identify areas in managing dangerous waste that must be addressed. Ongoing training of designated personnel will ensure that your facility complies with the law and that those employees are ready in an emergency.
MLI Environmental provides hazardous waste training services to help your facility stay compliant. To learn more, please get in touch with us today.