Caltha LLP provides expert RCRA, hazardous waste and universal waste consultant and compliance support to facilities in Minnesota. Under Federal RCRA laws, 40 CFR 262.34(a)(4), requires that large quantity generator (LQG) waste management personnel be trained in accordance with the requirements of 265.16.
40 CFR Parts 264.16 and 265.16 require facilities to train waste management personnel. Facility personnel must complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility’s compliance with the requirements of Section 265. The program must teach facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. At a minimum, the program must ensure that employees are able to respond to emergencies and must include training on emergency procedures, equipment and systems. Personnel must complete the training within six months of employment and take part in annual refresher training. For each employee, the owner or operator must maintain documentation of the job titles, employee names, job description, and the type and amount of training provided.
The EPA small quantity generator (SQG) regulations do not specify or give additional guidance on training requirements. Training for SQG facilities is generally less detailed than for Part 264/265 facilities.
Typical services Caltha provides to LQG and SQG facilities in Minnesota include:
- Presentation of annual RCRA training to affected employees
- Preparation of the facility RCRA Contingency Plan
- Determination of affected employees – who needs hazardous waste training?
- Emergency Preparedness and Emergency Response Plans
- Determination of disposal and recycling options
- Hazardous waste management program audits