24-Hour HAZWOPER Training for Large Quantity Generators of Hazardous Waste
On July 1 st, 2024, the California Department of Toxic Substances Control (DTSC) published the State’s version of the Federal Environmental Protection Agency’s (EPA) “Generator Improvement Rule” (GIR). As a result, there have been many (many, many) “operationally impactful” changes made to how hazardous waste is managed in California. As not to overwhelm you with all of the changes now (stay tuned for future blogs), we will thoroughly cover one major change and make reference to a second (the latter warranting to “headline” its own blog).
The changes, in respective order, pertain to training for large quantity generator (LQG) hazardous waste facility personnel and monthly generator status fluctuations. (As a side note, SCM fought many of these changes with diplomatic fervor during the rulemaking process.) Going forward (barring the passing of an emergency amendment sparked by the readers of this blog), the training requirements for LQGs, which must be completed within six months of hire (or within six months of assignment to a job requiring it), are fivefold:
The HAZWOPER entry is entered in bold type because of the fiscal burden this could place on your business, not to mention (even though we are…) that this requirement is much more stringent than EPA’s rule. With respect to HAZWOPER, EPA’s GIR simply requires hazardous waste personnel to be trained to respond to emergencies or trained to evacuate.
Notwithstanding, the 24-hour (initial) HAZWOPER training is not required if the facility can show (and document) that its personnel are trained in the following areas:
Hazard identification
Hazard evaluation
Hazard control/ risk mitigation methods
Emergency response procedures (e.g., evacuation and/or response)
Site analysis
Engineering controls
Maximum exposure limits
Hazardous waste handling procedures
Uses of new technologies
Hazard communication
Medical surveillance
Decontamination
Material handling (e.g., drums and containers)
In this case, an annual 8-hour refresher is needed. Another alternative to providing HAZWOPER training to employees is for the facility to hire hazardous waste contractors to manage its hazardous waste. The last point we’d like to touch on is related, yet adds another layer of difficulty to onsite hazardous waste management:
The challenges posed by 24-HAZWOPER training requirement is made more complicated now that California recognizes the status of hazardous waste generators on a monthly basis. This means that you can be a small quantity generator (SQG) in January, an LQG in February, a very small quantity generator (VSQG) in March… so forth and so on…. This is very problematic in that a small business that exceeds the SQG quantity limits due to a spill or clean-out is now subject to LQG training requirements and all of the other LQG requirements not covered in this blog.
SCM is still going to bat for State hazardous waste generators and will make our voices heard during “Phase II” of the California GIR rollout. In the meantime, it is important to know that if you are an LQG (even for one month) you must meet the fivefold training requirements detailed in Title 22 CCR §66262.17(a)(7)(A).
For more information, please take Hazmat School’s online Title 22 Training # 1399 and stay tuned!
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.
