DEEP: H/W Personnel Training

Hazardous Waste Personnel Training

Purpose
This fact sheet answers general questions and provides basic information on the personnel training that is required for large quantity generators of hazardous waste (LQGs). Small quantity generators (SQGs) also have training requirements, but they are different than the requirements for LQGs.  The DEEP’s Small Generator Guidance Document has detailed information on the training requirements that apply to SQGs.  The hazardous waste personnel training requirements for LQGs are found in Section 22a-449(c)-102(a)(1) of the Regulations of Connecticut State Agencies ("RCSA"), incorporating the federal hazardous waste regulations in 40 CFR 262.34(a)(4) and 265.16 .

This fact sheet is not intended to supersede the applicable regulations. You should refer to the appropriate statutes and regulations for specific regulatory language.  It is your responsibility to comply with all applicable laws and regulations.

Why Is Hazardous Waste Personnel Training Important?
The training of personnel involved in the management of hazardous waste is key to ensuring that hazardous wastes are handled properly, to preventing spills, fires, and other accidents, and to ensuring that any emergencies that do occur are responded to quickly and appropriately.  The hazardous waste regulations therefore require that LQGs provide hazardous waste training to all employees that have hazardous waste duties.

What Topics Must Covered in Personnel Training?
The hazardous waste personnel training program must be designed to ensure that facility personnel can respond effectively to emergencies by familiarizing them with emergency procedures, equipment and systems. In addition, the program must teach personnel the hazardous waste management procedures relevant to their positions and duties, unless those persons are under the direct supervision of someone who is responsible for ensuring that their duties are performed in compliance with these regulations. At a minimum, the program must include the following emergency response elements:

  1. Procedures for using, inspecting, repairing and replacing facility emergency and monitoring equipment;
  2. Key parameters for automatic waste feed cut-off systems;
  3. Communications and/or alarm systems;
  4. Response to fires, explosions and releases of hazardous waste constituents;
  5. Response to groundwater contamination incidents;
  6. Shutdown of operations;
  7. Evacuation procedures; and,
  8. Implementation of the facility contingency plan.
Who Should Be Trained?
Any facility personnel who perform hazardous waste-related duties, and/or are responsible for ensuring that the facility’s waste management procedures are in compliance with hazardous waste regulations must be trained. The training requirements are flexible and allow for different approaches to personnel training, depending upon each facility’s specific waste management issues and concerns.  Specific employees that must be trained include employees that:
  1. are responsible for complying with applicable waste management regulations (e.g., placing waste in containers or tanks, marking or labeling containers, moving waste from one location to another, loading containers on transportation vehicles);
  2. are responsible for responding to hazardous waste emergencies (e.g. emergency coordinators, spill response crews);
  3. make decisions that impact waste handling or management procedures (e.g. environmental or safety managers);
  4. are responsible for inspecting hazardous waste storage, treatment or disposal areas; or
  5. prepare or sign waste management documents, such as manifests.

When Must Training Be Conducted?
Facility personnel must successfully complete the training program within six months after their date of hire, or their assignment to hazardous waste duties within the facility.  Employees must not work in unsupervised positions until they have completed these training requirements.  In addition, facility personnel must take part in an annual review of the initial training program.  This annual review should incorporate any changes in regulatory requirements or the facility’s waste management or emergency procedures. 

With respect to annual reviews of training, DEEP interprets the term “annual” to mean that the review occurs within one year, or 365 days, of the initial training or the previous annual review.  However, DEEP recognizes that there are certain circumstances which may prevent every employee at a facility from receiving the required annual review within exactly 365 days of the previous training.  As a result, DEEP reviews compliance with this requirement on a case-by-case basis, taking into account any relevant factors, such as the facility’s overall training program, past compliance with training requirements, and how far outside the 365-day timeframe the annual review occurs.

Can Training Be Combined with Other Personnel Training Programs?
Yes. One training program can be modified to incorporate and meet the requirements of another program. For example, a facility’s Occupational Safety and Health ("OSHA") Hazardous Communication training program (29 CFR 1910.1200) can be modified to include all the required hazardous waste training elements. A word of caution, however:  training provided under other requirements such as OSHA that do not include all of the training elements listed above would not be sufficient.  No other training by itself is a one-for-one replacement for hazardous waste training.


Can Training Be Conducted In-House?
Yes, as long as the individuals conducting the in-house training have themselves been properly trained in hazardous waste management procedures such that they are sufficiently knowledgeable and qualified to instruct facility personnel.  For example, an LQG might send its environmental compliance manager for formal classroom training by a qualified training consultant, and this manager could then train facility personnel.  Other facilities have hired qualified training consultants to conduct the initial training, then had the annual updates conducted by qualified in-house staff.  Training can also take many forms.  For example, some elements may be covered via in-house safety meetings or by chemical and equipment suppliers, provided that the content is relevant to hazardous waste management.

How Must Personnel Training Be Documented?
LQGs are required to prepare and keep on file certain documentation of hazardous waste training to verify that company personnel have received the required training.  The required documentation includes:
  1. the name and job title of each employee involved in hazardous waste management;
  2. a written job description for each job title listed in item 1 above. This description must include the requisite skill, education or other qualifications, and duties of facility personnel assigned to this job title;
  3. a written description of the type and amount of both introductory and continuing training provided to facility personnel;
  4. records which document that training has been provided to, and completed by, all facility personnel listed under item 1 above. Such records may include, but are not limited to, trainee signature sheets and training certificates; and
  5. training records on current personnel, which must be kept until closure of the facility. Training records of former employees must be kept for at least three years from the date the employee last worked at the facility.  Personnel training records may accompany personnel transferred from one facility to another within the same company.
For further information, please contact the DEEP’s toll-free Compliance Assistance (COMPASS) hotline at 1-888-242-4193, or send us an email.

Content Last Updated December 29, 2016