Is Your TSDF Training Up to Date with RCRA Requirements?

One of the biggest challenges for managers of hazardous waste treatment, storage, and disposal facilities (TSDFs) is hitting all the training requirements. This is because Resource Conservation and Recovery Act (RCRA) regulations for TSDFs are more stringent than those for generators or transporters and include general facility standards as well as unit-specific design and operating criteria.

The general TSDF standards consist of good housekeeping provisions (e.g., security, inspections, and recordkeeping). The unit-specific technical requirements are designed to prevent the release of hazardous waste into the environment from each distinct type of facility.

TSDF Training—What You Have to Do

TSDF personnel must successfully complete a program of classroom instruction or on-the-job training designed to ensure the facility’s compliance with RCRA regulations. The instruction must be given by someone trained in hazardous waste management procedures; should be relevant to the individual jobs at the facility; and must include information to familiarize employees with emergency procedures, equipment, and systems so that they are able to respond effectively to emergencies.

The training program must include, where applicable:

  • Procedures for using, inspecting, repairing, and replacing emergency and monitoring equipment
  • Key parameters for automatic waste feed cutoff systems
  • Communications or alarm systems
  • Response to fire or explosions
  • Response to groundwater contamination incidents
  • Shutdown of operations

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Employees must undergo training within 6 months of the commencement of their employment or assignment to a new position at the facility.

Also, refresher training must be given annually.

Employers are required to maintain the following training records at the facility:

  • The job title of each hazardous waste position at the facility and the name of the employee filling the position
  • A written job description for each position at the facility, including 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 a position
  • Documentation that the required training has been given to and completed by facility personnel

Training records for current personnel must be maintained until closure of the facility.

Training records for former personnel must be maintained for 3 years from the employee’s last date of employment.

HAZWOPER Emergency Response Training Overlap

Facility employees that have received emergency response training under OSHA’s HAZWOPER rules do not need to receive separate emergency response training under RCRA rules as long as the overall training program includes all of the elements of the RCRA training requirements (40 CFR 264.16(a)(4)). For example, if a facility can meet all of the RCRA emergency response training requirements through a HAZWOPER training course, the EPA would consider the facility in compliance with the RCRA regulation. A facility must fill any gaps in training that may result. Facilities not subject to HAZWOPER training requirements must comply with the RCRA requirements.

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In tomorrow’s Advisor, we’ll cover what you need to know about HAZWOPER training for TSDFs, plus we’ll showcase a dynamic, online training resource of prewritten, interactive courses on more than 20 key environmental topics.

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