RCRA Hazardous Waste: Requirements, Training, and Certification

The Resource Conservation and Recovery Act (RCRA) is crucial in regulating the management and disposal of solid and hazardous waste in the United States. You want to ensure compliance with RCRA hazardous waste requirements to avoid costly penalties. The criminal penalties outlined in the Federal Code include violations of the treatment, storage, disposal, transportation, export, endangerment, record keeping, and making false statements.

Most violations carry penalties of two to five years imprisonment and/or up to $50,000 per day; awareness of endangerment is 15 years in prison and/or up to $1,000,000 if an organization or $250,000 for an individual. Neither your business nor your employees need that risk.

To ensure compliance with RCRA regulations, we will explain RCRA, training requirements, certification, and any additional HAZMAT classes your employees may require.

What Is RCRA?

The Resource Conservation and Recovery Act became law in 1976. The purpose is to regulate the disposal of hazardous and solid waste. This act, amending the Solid Waste Disposal Act of 1965, establishes national goals for protecting human health and the environment from potential hazards. RCRA's primary objectives include:

• Management of Hazardous Waste: RCRA sets standards for the treatment, storage, and disposal of hazardous waste. It establishes a cradle-to-grave system, ensuring proper handling from generation to final disposal.
• Solid Waste Management: RCRA addresses the management of non-hazardous solid waste as well, emphasizing resource conservation, recycling, and safe disposal methods.
• Landfill Regulation: The Act regulates the design and operation of landfills and other disposal facilities to minimize environmental impacts and protect public health.
• Corrective Action: RCRA mandates cleanup and corrective actions for sites contaminated by hazardous waste, ensuring responsible parties address environmental hazards.
• Underground Storage Tanks: It regulates underground storage tanks to prevent leaks and protect groundwater from contamination.

Who Needs RCRA Training?

If your business manages hazardous waste, you must ensure compliance with RCRA regulations. All employees who generate, store, treat, or dispose of hazardous waste must have certification.

The frequency of mandatory training updates depends on the hazardous volume generated. All employees responsible for the above tasks must receive training within six months of their initial hire date pursuant to 40 CFR § 260.10. The code also requires an eight-hour refresher course yearly.

The training prevents spills, protects employees, and avoids EPA penalties. Learning EPA standards of 40 CFR Part 262 allows employees to properly manage, label, keep records, and comply with reporting requirements regarding hazardous waste accumulation.

Determining the necessary training requires analyzing the company's production of hazardous materials. Once a material is determined to be hazardous, the generator must assess the extension of applicable regulations.

This A to Z RCRA hazardous waste list makes it easy to find the item your company is discarding. All states must comply with federal regulations but may also enact codes that exceed federal standards.

Determine if your company is at risk of non-compliance with regulations and ensure everyone is appropriately certified for handling waste. HAZMAT regulations are constantly changing, with several updates taking place in 2023.

RCRA Hazardous Waste Records

The owner or operator of a business must maintain specific records at the facility that contain the title of each position dealing with hazardous waste management and the name of the employee holding that position. The record must also include the job description and all initial and continuing training that person has received.

Businesses must retain records of current HAZMAT personnel until the facility closes and on former employees for a minimum of three years from their last date of employment.

RCRA Training Requirements

The Code of Federal Regulations § 265.16 requires personnel to complete classroom instruction or on-the-job training on performing duties to ensure compliance. They must also participate in an annual training review.

Instruction must be by someone trained in hazardous waste management procedures. The training must ensure personnel know how to respond to emergencies and are familiar with proper emergency procedures, equipment, and systems, including:

• Alarm systems and communications
• Explosive or fire response procedures
• Groundwater contamination response
• Operations shutdown
• How to use, inspect, repair, and replace emergency and monitoring equipment
• Parameters of automatic waste feed cut-off systems

If an employee receives OSHA emergency response training, separate emergency response training is not necessary as long as the OSHA training meets all the requirements.

RCRA certification training requires a minimum of 16 hours to complete. This course covers all safety standards for hazardous waste and emergency preparation, reporting, and recordkeeping.

Anyone in your company who handles, generates, stores, manages, transports, counts, inspects, marks, labels, or moves hazardous containers must receive this training. Under 40 CFR § 265.16, an annual refresher is mandatory.

HAZMAT Certification Classes

There are nine HAZMAT classes. Each class covers a particular material:

• Explosives
• Gases
• Flammable Liquids
• Flammable Solids
• Oxidizing substances and organic peroxides
• Toxic substances
• Infectious substances,
• Radioactive materials
• Corrosive substances
• Miscellaneous dangerous goods

Depending on your industry, specialty training areas may be necessary.

DOT HAZMAT Awareness

Anyone who handles the packaging, labeling, marking, and transporting of hazardous materials must follow the Hazardous Materials Regulations (HMR) regulations. Online certification classes provide the instruction necessary to comply with 49 CFR Parts 100 through 185 regarding hazardous materials transportation.

The Department of Transportation can enforce these regulations per the Pipeline and Hazardous Materials Safety Administration (PHMSA). Other agencies with the same authority include the FAA, FRA, FMCSA, PHMSA, and the U.S. Coast Guard.

HAZWOPER Certification

OSHA requires 40 hours of HAZWOPER training before handling hazardous waste operations. This includes emergency response, cleanup, removal, or any other job where exposure is possible.

The HAZWOPER 40 certification provides employees with the initial mandatory training and covers all operations, including emergency response standards. Recommendations are that the online training be paired with job-specific on-site training to provide employees with hands-on experience necessary to ensure training levels are appropriate for job requirements.

Choose CTO for Your Certification

Compliance Training Online has the highest ratings and industry trust of any online training provider. Over 31,600 companies, government agencies, and universities use our online courses. We've been committed to our up-to-date, flexible training programs since 2008. To learn about all courses available, check out our online course catalog or contact us.