The Resource Conservation and Recovery Act (RCRA) gives the EPA the authority to control hazardous waste – which includes the generation, transportation, treatment, storage, and disposal of hazardous waste. The RCRA is the law that creates the framework for the proper management of hazardous and non-hazardous solid waste. The RCRA regulations are contained in Title 40 CFR Parts 239 – 282.
Mandated Required RCRA Training
The EPA requires RCRA Training for persons working on-site at a Large Quantity Generator (LQG) of hazardous waste who handle hazardous waste as part of their job (i.e. ‘RCRA Personnel’ or ‘Hazardous Waste Personnel’). It may include part-time or temporary workers, contractors, consultants, and off-site managers.
RCRA Annual Refresher training is also required for all personnel whose job responsibilities bring them into contact with hazardous waste or will respond to a hazardous waste emergency.
The RCRA refresher training course is designed to satisfy EPA’s annual training mandate for hazardous waste personnel and covers the RCRA management, storage, and disposal requirements for hazardous waste generators under 40 CFR Parts 260-279.
Cal-EPA RCRA Regulations
California has unique hazardous waste regulations that include, but substantially exceed requirements of the Federal RCRA regulations generally in effect in other states. California has requirements that include rules for not just generators, but also transporters, hazardous waste treatment and storage facilities along with specific guidelines for treatment and disposal practices. Also, the state regulates more wastes as hazardous wastes than the Federal Rules (among other rules); meaning it may not be deemed hazardous by Federal Codes, but may be considered hazardous by state or local municipal code or ordinances.
California hazardous waste training is required annually for all personnel “who work at, or oversee the operations of, a hazardous waste facility and whose actions or failure to act may result in noncompliance.” California’s hazardous waste regulations are stricter and more intricate than the Federal rules. Cal/EPA fines for noncompliance are as high as $25,000.
RCRA Training Overview
RCRA Refresher Training – 8hrs
The RCRA/EPA Hazardous Waste Management Annual Refresher Certification was developed to keep you and your management staff ahead of the State and Federal laws governing compliance, with 40 CFR 262.34 and 265.16.
After completing the “Initial” Hazardous Waste Management training, the EPA requires you complete an annual refresher to stay current of changes in regulations and to refresh the student’s knowledge the EXTENSIVE regulatory requirements contained in this training.
The Environmental Protection Agency (EPA), requires all facilities that generate hazardous waste, have training that includes detailed regulatory requirements. Training topics include: Emergency response, waste characterization, transportation container marking and labeling, waste minimization, and manifesting.
Newly updated! Fully interactive training written by industry experts!
Hours: 8 hours
There are no regulatory requirements listed for this course, but this refresher course and is intended for individuals who are familiar with both RCRA and DOT requirements. It is not recommended as initial training.
This course is intended for environmental professionals who are:
- Involved with handling, shipping, or receiving hazardous materials, including samples of hazardous waste; and
- Involved with managing hazardous wastes. This may include engineers; scientists; geologists; facility personnel; field technicians; samplers; drillers; laboratory technicians; and shipping & receiving personnel.
California Title 22 Hazardous Waste Training Topics:
- Key regulatory terms and Title 22 structure
- Identifying RCRA and non-RCRA hazardous wastes
- Managing “extremely hazardous wastes” and “wastes of concern”
- California’s Unified Program and CUPAs
- Regulatory and statutory exclusions to streamline your operations
- Options for on-site accumulation and storage (90-day, 180-day, satellite areas)
- Rules for universal waste, used oil, treated wood waste, and spent-lead batteries
- Emergency preparedness and contingency planning
- Pre-transport requirements for RCRA and non-RCRA wastes
- Completing the Uniform Hazardous Waste Manifest
- Recordkeeping, reporting, and training requirements
At the conclusion of this course, you will be able to:
- Explain the importance of RCRA regulations in managing hazardous wastes.
- Describe the standards used for different types of hazardous waste treatment, storage, and disposal facilities.
- Implement hazardous waste management systems to achieve and maintain compliance.
- Discuss the financial assurance requirements for corrective actions under RCRA.
- Discuss a manifest system including discrepancies, unmanifested waste, and operating records.
- Identify requirements for the monitoring, recordkeeping, and closure procedures of hazardous waste.
- Properly identify hazardous wastes according to RCRA regulations.
- Discuss the elements of a waste management system for municipal solid waste and industrial waste.
Per EPA regulations, Individuals who complete the Hazardous Waste Generator Training required under 49 CFR 262.34 and 265.16 must complete an ANNUAL refresher course that covers the 12 sections outlined in EPA’s training requirements including:
- History of the RCRA Law
- Solid Waste, Hazardous Waste, and Recycling
- Summary of Regulations for Generators of Hazardous Waste and TSDFs
- Generator Regulations
- Transporter Requirements
- HAZWOPER (Hazardous Waste Operations and Emergency Response)
- Incinerators, Boilers, and Industrial Furnaces
- RCRA Air Emission Standard
- TSD Facility Requirements
- Used Oil Management
- Land Disposal Restrictions
- Underground Storage Tanks
Module Quizzes and Final Exam
All module quizzes require a score of 70% to proceed forward in the course. The exam will test your knowledge on information covered throughout the course. You must make a score of at least 70% to pass this course. You will be given up to three opportunities to pass each quiz and the final exam. If you do not pass after three tries, you will be locked out of this course will no longer be able to take your Outreach training in an online format.
Course Completion Certificate
Upon successful completion of the course, you will receive a printable certificate of completion which is accepted by OSHA as documentation of training.
- 40 CFR 265.16, 40 CFR 262.34(d)(5)(iii), 40 CFR 261.5, and 49 CFR 172.704 (Subpart H).
- In addition to the initial RCRA training, 40 CFR265.16(c) requires “facility personnel must take part in an annual review of the initial training.”
- The training requirements for SQGs are found in 40 CFR Part 262.34(d). SQGs must ensure that their workers are: “…thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies”. This may require annual training by a facility or some other type of instruction appropriate to the wastes handled at the SQG site.
- DOT’s training requirements for shipping hazardous materials are located in 49 CFR Part 172 Subpart H.
- In addition to initial training [49 CFR 172.704(c)(1)], DOT requires “recurrent training” every 3 three years. “A hazmat employee shall receive the training required by this subpart at least once every three years.” [49 CFR 172.704(c)(2)].
- DOT requirement for refresher training is only once every three (3) years.
- Refresher Training Required: Every 1 year(s).
The California Hazardous Waste Control Law (HWCL)
The California Hazardous Waste Control Law (HWCL) [California Health and Safety Code §§ 25100, et seq.] was enacted in 1972, fully four years prior to enactment of the federal Resource Conservation and Recovery Act (RCRA) in 1976. This simple piece of background information explains the reason for many of the differences between California and federal hazardous waste requirements; for example:
- The HWCL says that all hazardous waste treatment had to be permitted or authorized by the Department of Toxic Substances Control (DTSC). RCRA exempted many forms of treatment by generators when enacted.
- California law authorized adoption of a list of hazardous wastes (22 CCR § 66261, Appendix X) more than 10 years prior to RCRA listed hazardous wastes (40 CFR § 261), and a toxicity characteristic more than 10 years before the RCRA counterpart.
- RCRA has“sewer exclusion” for wastes subject to Clean Water Act regulation. There is no sewer exclusion in state law, as confirmed by state courts (Peo. v. Sangani).
- Excluded recyclable materials are a matter of federal regulation under RCRA; state law in California.
These examples of the fundamental differences between RCRA and California hazardous waste law are only the tip of the iceberg compared to regulatory differences. More examples based on state regulations:
- Hazardous waste toxicity characteristic includes a score of constituents not federally regulated, like copper, zinc, fluorides, nickel, etc.
- The state toxicity characteristic includes soluble constituent limits like the federal characteristic, but also total constituent limits.
- The state’s expanded toxicity characteristic includes other criteria, like presence of carcinogens and bioassay testing (aquatic 96-hour acute toxicity test).
- There is a solid corrosively characteristic.
- Any RCRA hazardous waste excluded from regulation is a California-only non-RCRA hazardous waste unless state law or regulation excludes it.
- Waste lubricating oil is a hazardous waste.
- There is no conditionally exempt small quantity generator relief in the state
- There are many more universal wastes and similarly regulated hazardous wastes, like treated wood waste, in California.
RCRA EPA Resources
More About RCRA 8hr Refresher Training Courses
Congress enacted the RCRA to address the increasing problems the nation faced from its growing volume of municipal and industrial waste. RCRA, which amended the Solid Waste Disposal Act of 1965, set national goals for:
- Protecting human health and the environment from the potential hazards of waste disposal.
- Conserving energy and natural resources.
- Reducing the amount of waste generated.
- Ensuring that wastes are managed in an environmentally-sound manner.
RCRA in Day to Day Operations – 2hrs
Resource Conservation and Recovery Act (RCRA) is designed to track hazardous waste from cradle to grave. Under RCRA, hazardous waste generators are the first link in the cradle-to-grave hazardous waste management system.
This RCRA Training course covers RCRA regulations relating to generators, containers, and hazardous waste management plan (HWMP). The goal of HWMP is to handle hazardous waste in a safe, efficient, and environmentally sound manner and to comply with RCRA regulations.
RCRA: What the Law Requires – 4hrs
This RCRA Training course explains the history of the Resource Conservation and Recovery Act (RCRA), its structure and its key elements that provide the framework for the U.S. Environmental Protection Agency’s (EPA) comprehensive waste management program. The course discusses the specific requirements of various types of facilities that treat, store, transport or dispose of hazardous waste.
Resource Conservation and Recovery Act (RCRA) Orientation Manual
This manual provides introductory information on the solid and hazardous waste management programs under the Resource Conservation and Recovery Act (RCRA). Designed for EPA and state staff, members of the regulated community, and the general public who wish to better understand RCRA, this document constitutes a review of the RCRA program and is not a substitute for RCRA or its implementing regulations. The manual comprises seven sections plus appendices:
- Introduction to the Resource Conservation and Recovery Act;
- Managing Solid Waste – RCRA Subtitle D;
- Managing Hazardous Waste – RCRA Subtitle C;
- Moving Forward: Materials Management and Resource Recovery;
- Miscellaneous Statutory Provisions;
- RCRA and its Relationship to Other Environmental Statutes; and
- Public Participation in the RCRA Program.
- Resource Conservation and Recovery Act Orientation Manual 2014 (PDF)
(242 pp, 8 MB, October 2014, EPA530-F-11-003)
RCRA Tools and Resources
RCRA Resources for State Officials
RCRA Training Modules
The EPA developed training modules that provide an overview of hazardous waste regulatory topics. These courses are not intended to serve as comprehensive sources of regulatory information.
- Air Emission Standards
- Boilers and Industrial Furnaces
- Containment Buildings
- Corrective Action
- Definition of Solid Waste and Hazardous Waste Recycling
- Drip Pads
- Enforcement and Compliance
- Financial Assurance
- Groundwater Monitoring
- Hazardous Waste Identification
- Hazardous Waste Incinerators
- Land Disposal Restrictions
- Land Disposal Units
- Miscellaneous and Other Units
- Municipal Solid Waste Disposal Facility Criteria
- Permits and Interim Status
- Petitions, Delistings, and Variances
- Solid Waste Programs
- State Programs
- Statutory Overview
- Treatment, Storage, and Disposal Facility Criteria
- Used Oil
- Universal Waste
The RCRA regulations are contained in Title 40 of the Code of Federal Regulations (CFR) – Protection of Environment: Parts 239 through 282 (See below).
In any given state, EPA or the state’s hazardous waste regulatory agency enforces hazardous waste laws. EPA encourages states to assume primary responsibility for implementing a hazardous waste program through state adoption, authorization and implementation of the regulations.
Title 40 of the CFR parts 239 through 259 contain the regulations for solid waste. The requirements for underground storage tanks, which are also regulated under RCRA, are located in title 40 CFR part 280. A list of all solid waste regulations with links to the regulatory text is provided below:
- Part 239 – Requirements For State Permit Program Determination Of Adequacy
- Part 240 – Guidelines For The Thermal Processing Of Solid Wastes
- Part 243 – Guidelines For The Storage And Collection Of Residential, Commercial, And Institutional Solid Waste
- Part 246 – Source Separation For Materials Recovery Guidelines
- Part 247 – Comprehensive Procurement Guideline For Products Containing Recovered Materials
- Part 254 – Prior Notice Of Citizen Suits
- Part 255 – Identification Of Regions And Agencies For Solid Waste Management
- Part 256 – Guidelines For Development And Implementation Of State Solid Waste Management Plans
- Part 257 – Criteria For Classification Of Solid Waste Disposal Facilities And Practices
- Part 258 – Criteria For Municipal Solid Waste Landfills
- Part 259 [Reserved]
The regulations governing hazardous waste identification, classification, generation, management and disposal are found in title 40 CFR parts 260 through 273.
- Part 260 – Hazardous Waste Management System: General
- Part 261 – Identification And Listing Of Hazardous Waste
- Part 262 – Standards Applicable To Generators Of Hazardous Waste
- Part 263 – Standards Applicable To Transporters Of Hazardous Waste
- Part 264 – Standards For Owners And Operators Of Hazardous Waste Treatment, Storage, And Disposal Facilities
- Part 265 – Interim Status Standards For Owners And Operators Of Hazardous Waste Treatment, Storage, And Disposal Facilities
- Part 266 – Standards For The Management Of Specific Hazardous Wastes And Specific Types Of Hazardous Waste Management Facilities
- Part 267 – Standards For Owners And Operators Of Hazardous Waste Facilities Operating Under A Standardized Permit
- Part 268 – Land Disposal Restrictions
- Part 270 – EPA Administered Permit Programs: The Hazardous Waste Permit Program
- Part 271 – Requirements For Authorization Of State Hazardous Waste Programs
- Part 272 – Approved State Hazardous Waste Management Programs
- Part 273 – Standards For Universal Waste Management
Other RCRA regulations
EPA also established regulations for managing used oil and standards for underground storage tanks, which can be found in title 40 CFR parts 279 through 282.
- Part 279 – Standards For The Management Of Used Oil
- Part 280 – Technical Standards And Corrective Action Requirements For Owners And Operators Of Underground Storage Tanks (UST)
- Part 281 – Approval Of State Underground Storage Tank Programs
- Part 282 – Approved Underground Storage Tank Programs
- Parts 283 to 299 [Reserved]
Meets Cal-EPA Standards
California requires annual hazardous waste RCRA training – for all personnel “who work at, or oversee the operations of, a hazardous waste facility” – which substantially exceed requirements of the Federal RCRA regulations.
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- Meets Latest EPA & Cal-EPA Standards
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RCRA Training – 8hrs
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