RCRA Training | RCRA Hazardous Waste Generator Training

RCRA Label Information

A label will tell employees

The name of the chemical—common name, chemical name, or both. If the substance contains more than one chemical, they'll all be listed unless they are a "trade secret".

The name, address, and emergency telephone number of the company that manufactured or imported the chemical.

The chemical's physical hazards—what could happen if the chemical is not handled properly. Is it flammable or combustible? explosive? Is it reactive? radioactive?

The chemical's health hazards, or possible health problems that could result from overexposure. Some of the terms that describe health hazards are carcinogen (causes cancer), highly toxic (poisonous) agent, toxic agent, reproductive hazard, irritant (temporarily inflames tissue), corrosive (destroys tissue), sensitizer (causes an allergic reaction after repeated exposure), hepatotoxin (produces liver problems), nephrotoxin (damages kidneys), and neurotoxin (causes nervous system problems).

Some labels also include important information such as storage and handling instructions. This could include such information as "use only in well-ventilated areas" or "store in tightly closed containers".

Basic protective clothing, equipment, and procedures that should be used to work safely with the chemical might also be listed. These might include "avoid contact with skin," "use eye protection," etc.

Words, Pictures, Symbols
Special signal words are used on many labels to quickly tell how dangerous the chemical could be. Common signal words and their meanings are

Danger—can cause immediate serious injury or death. It may refer to a substance that is extremely flammable, corrosive, or toxic.

Warning—can cause potentially serious injury or death.

Caution—can cause potentially moderate injury.

RCRA Training Special Symbols

Special symbols that may include HAZWOPER work are also used on many labels to depict the kinds of hazards the chemical could present. These are required as well as RCRA training hazardous waste labels. These symbols appear on labels of containers that have been shipped by truck, rail, or air: the skull-and-crossbones symbol for poison, used to identify toxic substances; flames to indicate flammability; an object blowing apart to warn of explosion danger; and a drip that eats away at a hand or an object to warn of corrosion.

RCRA HAZARDOUS WASTE MANAGEMENT TRAINING

Who must Receive RCRA Training?

Under the Resource Conservation and Recovery Act (RCRA) regulations small quantity generators (SQG) and large quantity generators (LQG) of hazardous wastes are required to provide personnel with initial training within 6 months of employment or assignment to a new position with hazardous waste management tasks and annual training there after.

A SQG generates between 100 kilograms (220 lbs.) and 1,000 kilograms (2,200 lbs.) of non-acute hazardous waste and no more than 1-kilogram (2.2 lbs.) of acute hazardous waste per calendar month. A SQG can store hazardous waste for 180 days or less but the storage amount cannot exceed 6,000 kilograms (13,200 lbs.). RCRA training is required.

A LQG generates 1,000 kilograms (2,200 lbs.) or more of non-acute hazardous waste or more than 1 kilogram (2.2 lbs.) of acute hazardous waste per calendar month. A LQG can store hazardous waste for 90 days or less. For a LQG, all "facility personnel" are required to receive this training. Facility personnel are defined under 40 CFR 260.10 as "all persons who work at, or oversee the operations of, a hazardous waste facility, and whose actions or failure to act may result in noncompliance with the requirements of part 264 or 265". Although this definition is vague, EPA has indicated in various guidance documents and memos, individuals who perform one or more of at least the following hazardous waste functions are required to receive hazardous waste training:

• Label hazardous waste containers;

• Move hazardous waste containers;

• Perform inspections;

• Perform the functions of an emergency coordinator; and

• Prepare, review, or sign hazardous waste manifests.

A SQG must "ensure that all employees are thoroughly familiar with proper waste- handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies". To clarify who is required to receive hazardous waste training, EPA indicated in a regulatory preamble "employees who handle hazardous waste as part of their normal job responsibilities or are likely to handle wastes in an emergency situation must be thoroughly familiar with proper waste handling and emergency procedures". In general, personnel who perform the functions listed above for LQGs and SQGs are required to receive hazardous waste training.

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