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Annual Hazardous Waste Training

The Annual Hazardous Waste Training task is part of the Hazardous Waste compliance program on Complyrs.

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Overview

Businesses that generate hazardous waste must provide training for employees tasked with handling hazardous waste. The training should cover information about how to do the following:

  • Protect worker safety
  • Protect the environment
  • Ensure compliant handling of hazardous waste
  • Ensure appropriate responses to emergencies

Small Quantity Generators

Small quantity generators (SQG) (less than 1,000 kg/month) of hazardous waste must provide training that ensures employees are familiar with:

  • Proper waste handling
  • Emergency procedures

While it is not required it is recommended that every business has a written training plan and maintains records of training events.

Large Quantity Generators

Large quantity generators (more than 1,000 kg/ 2,200 lbs or more per month) must comply with the following more stringent training requirements:

  • Provide training that ensures personnel know how to perform their duties in a way that ensures the generator’s compliance with the regulatory requirements.
  • Training must be directed by a person trained in hazardous waste management procedures and must include instruction on:
    • Hazardous waste management procedures
    • Contingency plan implementation, including emergency response, emergency equipment, and emergency systems
  • New personnel must be trained within six months after employment
  • Personnel must not work in unsupervised positions until they have completed the training course
  • Training must be renewed annually

Documentation

The following documents and records must be maintained at the facility.

  • The job title for each position related to hazardous waste management, and the name of the employee filling each job.
  • A written job description for each position related to hazardous waste management, including the requisite skill, education or other qualifications and duties of employees assigned to each position.
  • A written description of the type and amount of both introductory and continuing training that will be given to each person filling each of these positions.
  • Records of training for facility personnel.
  • Training records on current personnel must be kept until closure of the site.
  • Training records on former employees must be kept for at least three years from the date the employee last worked at the site.
  • Personnel training records may accompany personnel transferred within the same company.

Resources

Washington State Department of Ecology: Template to help businesses develop LQG training plans

LA County Fire: Fact Sheet on Large Quantity Generator Training Requirements

Unidocs: Training Record Form  

References

California DTSC: Hazardous Waste Generator Requirements

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