Hazardous Waste Operations (Hazwoper) Training, related to operations and emergency response, is required for all applicable construction and general industry employees. Per the Occupational Safety and Health Administration OSHA, applicable employees include those tasked with:
- Clean-up operations at locations for which the Resource Conservation and Recovery ACT (RCRA) applies;
- Clean-up actions performed voluntarily at sites that a government has designated an uncontrolled hazardous waste site;
- Any work in uncontrolled hazardous waste areas that entails corrective actions on hazardous substances;
- Emergency response operations either when there is a high threat of a hazardous substance release or when a release has occurred; and
- Any work involving hazardous waste that is performed in RCRA-licensed storage, disposal, or treatment facilities.
The standards for hazardous waste are similar for those states that use the Environmental Protection Agency (EPA)’s standards and 26 states that have OSHA-approved state plans in place.
General Hazardous Waste & RCRA Requirements
To handle material properly and maintain hazardous waste certification, there must be training for everyone who works on-site. There must also be programs for health and safety, emergency response, medical surveillance, new technology, and decontamination.
Beyond those requirements, RCRA sites also need the following:
- Drum and container control and handling procedures; and
- A hazard communication program, in writing that meets the standards of 29 CFR 1910.1200.
Hazwoper Training Requirements
Here are the training needs for various facilities and scenarios:
RCRA-licensed Treatment, Storage and Disposal Facility (TSDF) training
Uncontrolled HazWaste site cleanup or non-RCRA-licensed emergency response operations
- Awareness-level first responders – Must know HazWaste identification, risks, and their emergency responsibilities
- Operations-level first responders – Beyond awareness, need 8 hours of training
- On-scene incident commanders – Ability to operate the incident command system, know the local and state emergency response parameters, understand the business’s plan, and have 24 hours of operations-level training
- Hazardous waste materials technicians – Must know the decontamination procedure, emergency response plan and have 24 hoursof operations-level training
- Hazardous materials specialists – Must interact with government regulators and have 24 hoursof technical-level training.
8-hour refresher training is needed each year for all response levels.
RCRA Hazardous Waste Management Training
You may need specialized RCRA hazardous waste training. Here are RCRA hazardous waste training requirements for various facilities, as outlined in EHS Daily Advisor:
There must be an overview of initial and ongoing training within the initial permit for any hazardous waste facility. The HazWaste training must enable operators and managers to get personnel the information they need to safely run the facility.
Treatment, Storage, and Disposal Facility (TSDF)
In order to verify the TSDF’s EPA compliance, employees must complete on-the-job or classroom RCRA training. The training should be flexible, so it is relevant to all job roles. The instructor should provide plenty of opportunities to answer questions.
- Initial training – 24 hours
- Annual refresher – 8 hours.
Systems, equipment, and emergency procedures that must be covered within these institutions’ RCRA training courses include the following:
- Groundwater, fire, and explosion response;
- Alarm systems and communications;
- Feed cutoff systems for automatic waste; and
- Monitoring and emergency equipment inspection, repair & replacement.
Whenever an employee is newly hired or switches their role at a TSDF, they must receive training within 6 months. Continuing education is needed once per year.
Large Quantity Generator (LQG)
A generator becomes a storage facility if they have hazardous waste on-site for over 90 days – in which case they must follow TSDF training that leads to RCRA certification. Those that have HazWaste on-site for 90 days or under without a permit must follow TSDF hazardous waste training parameters.
Small Quantity Generator (SQG)
You do not need to have formal documented RCRA training classes in place if you are an SQG. Nonetheless, you need to make sure that everyone working at your facility knows the correct emergency response procedures and waste-handling best practices.
Emergency Response is Fundamental
Training is required before employees engage in hazardous waste operations and emergency response. Management of any emergencies that arise on-site, alongside response activities, is the focus of an emergency response plan. The plan is the basis of your training for emergency response. Per OSHA, this plan should include guidance/instructions for the following:
- How to identify and prevent emergencies
- How to evacuate (procedures and routes)
- What the chain of command is
- How to communicate with personnel
- How to train your employees
- How to define, introduce, and manage employee roles
- How to deliver emergency medical care
- What to expect for emergency alerts (procedures)
- How to decontaminate (procedures)
- How to secure the site.
The plan should be assessed and updated at regular intervals, per OSHA. Emergency response training should also be further ingrained through routine drills.
Cohesion & Compliance
For compliance, you need cohesion – so your safety and compliance training must get your team on the same page. At AOTC, our training classes are designed to ensure key safety competencies are understood and duplicated by each student. Contact us today to schedule your custom training courses.