Generators and shippers of hazardous waste need to be cognizant of what training is required before signing any shipping papers. Training is regulated under both RCRA (Resource Conservation and Recovery ACT) and US Department of Transportation (DOT) Regulations.
There are no training requirements under RCRA specific to signing a hazardous waste manifest, however generators are still required to follow training requirements under 40 CFR Part 262 or Part 265 (depending on your generator status). Click here to review the training requirements under RCRA for Generators of Hazardous waste.
In addition to complying with RCRA regulations for generators of hazardous waste, the EPA’s requirements for preparing and signing a manifest are based on USDOT regulations. By definition, all RCRA regulated Hazardous Wastes are also USDOT Hazardous Materials.
USDOT Regulations for training are defined in 49 CFR Part 172, Subpart H-Training. These regulations state that employees must have general awareness/familiarization, function-specific training, and safety/security training. This training is required within 90 days of employment for a new employee and then re-occur every 3 years after.
Anyone who offers a hazardous material for transportation is signing a document that contains the following certification:
“I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition for transport according to applicable international and national government regulations…”
In essence, if a person is a signing a document certifying the above to be true, the “function-specific training” the employee receives should be related to classification of materials, packaging, marking, labeling, placarding etc.. The employee needs to be knowledgeable in all areas stated above to be able to ensure a shipment is compliant with the Hazardous Materials Regulations. As stated, this training to show competency in the areas relevant to the signing of hazardous waste manifests should be repeated every three years to remain in compliance.