A RCRA certification refers to fulfilling the training requirements outlined by the Resource Conservation and Recovery Act (RCRA) for anyone who handles or manages hazardous waste. This training ensures that personnel are knowledgeable about the regulations and can perform their duties safely and compliantly.
Here’s a breakdown of how to get RCRA training and meet the requirements:
1. Determine Your Generator Status
Your first step is to know your facility’s hazardous waste “generator status,” as this determines the specific training you need. The EPA classifies generators into three categories:
- Very Small Quantity Generators (VSQGs): Generate 100 kg or less of hazardous waste per month. While the regulations don’t explicitly require formal training, it is highly recommended as you are still responsible for proper waste management.
- Small Quantity Generators (SQGs): Generate more than 100 kg but less than 1,000 kg of hazardous waste per month. Employees must be “thoroughly familiar” with proper waste handling and emergency procedures relevant to their job.
- Large Quantity Generators (LQGs): Generate 1,000 kg or more of hazardous waste per month. This category has the most stringent requirements.
2. Take the Required Training
RCRA training must be provided to personnel whose actions or inaction could lead to non-compliance with the regulations. This includes anyone involved in:
- Identifying and classifying waste.
- Managing waste in satellite or central accumulation areas.
- Inspecting containers.
- Filling out hazardous waste manifests.
- Responding to spills.
The training can be delivered in a few ways:
- Online Courses: Hazmat School offers self-paced online RCRA course or Title 22 Hazardous Waste course live webinar-based training that meets the federal requirements. This is a very common and flexible option.
- In-person Workshops: Some training providers offer classroom-style seminars. SCM Safety offers a great interactive class in the Bay Area.
- On-the-Job Training: Your employer may have an in-house program directed by a person who has been trained in hazardous waste management procedures.
Key Training Requirements:
- Initial Training: All new hazardous waste personnel at an LQG must complete their training within six months of being hired or assigned to their new role. Until they are fully trained, they must be supervised by a trained employee.
- Refresher Training: For LQGs, an annual refresher training is required to keep personnel up-to-date on any changes in regulations and to review procedures
3. Maintain Documentation
The training itself is only part of the process. Your employer is legally required to maintain detailed records to prove that all personnel have been trained. These records should include:
- The employee’s name and job title.
- A written job description.
- A description of the type and amount of training.
- Proof that the training was completed (e.g., a certificate of completion).
These records must be kept at the facility until it closes and for a minimum of three years after a former employee’s last date of employment.
State-Specific Regulations
It’s crucial to remember that many states have their own, more stringent RCRA regulations. The federal requirements are a baseline, and you may need to complete additional training specific to your state. For example, some states have different requirements for Very Small Quantity Generators or different annual training mandates. Always check with your state’s environmental agency to ensure you are fully compliant.
Manages Hazmat School’s E-Learning courses and blog. Kirstie has extensive experience in the online training and education industry. Kirstie has worked with courses that offer a variety of safety and environmental certifications that satisfy OSHA, EPA and DOT requirements.
