DOT Hazardous Materials Update

During our ISO 14001 and EHS compliance audits we continue to write findings for organizations that do not fully understand the training requirements under the DOT and RCRA Hazardous Waste regulations.  Here is a brief regulatory discussion and our training program.

DOT HMR rules defines who is considered a “Hazardous Materials Employee” at 49 CFR 171.8 and the required training at 49 CFR 172.704. 49 CFR 172.704 (d) says  “the hazmat employer must create records of Certification that the hazmat employee has been trained and tested, as required by this subpart”

RCRA Hazardous Waste training requirements are define based on the Generator Status of the organization (Large Quantity, Small Quantity, or Very Small Quantity) and the specific training requirements can be found at:

Large Quantity Generators: 

  • Hazardous waste personnel must be trained within six months of hire/assignment and may not work unsupervised until training is complete [40 CFR 262.17(a)(7)(ii)].
  • Hazardous waste training must be repeated annually [40 CFR 262.17(a)(7)(iii)].
  • Employers must keep records of hazardous waste training [40 CFR 262.17(a)(7)(iv)].

Small Quantity Generators ( < 1000 kg per month )

  • Hazardous waste personnel must be “thoroughly familiar” with their responsibilities for hazardous waste management compliance [40 CFR 262.16(b)(9)(iii)].

Very Small Quantity Generators ( < 100 kg per month )

  • No regulatory required training. However, ISO 14001 does require employees with these responsibilities to be “competent” based on training, education, and experience.

On May 14 we are offering online training to support your compliance in both of these areas:

  • DOT General Awareness Training – 2 hours – The 2-hour webinar will provide a brief overview of the DOT Hazardous Materials regulation (49 CFR 172), material classification using the Hazmat Table, package selection, labeling / marking, shipping papers and placarding requirements. This introductory program designed to meet DOT requirements for general awareness requirements.
  • RCRA Hazardous Waste Training – 2 hours – This webinar will provide an overview of the RCRA hazardous waste management regulations and requirements for Large, Small, and Very Small Hazardous Waste Generators. Training will include:
    •    Hazardous waste characterization (some exemptions)
    •     Universal Waste Management
    •     Determining generator status
    •     Accumulation requirements
    •     Container Labeling
    •     Per-transpiration
    •     Manifesting
    •     Inspections
    •     Record Keeping
    •     Emergency response requirements
    •     Common non-compliance issues

The schedule for future classes can be found at – DOT/RCRA Webinar. We are planning to schedule these webinars quarterly.

Each course will provide electronic copies of the training materials, brief quiz, and training certificate.

Please SHARE with other who may be interested. Thank you!!!

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