DOT training for CESQG Hazardous Waste Generators

CESQG hazardous waste generators generate very low quantities of hazardous waste and ship them very infrequently. They typically hire qualified waste disposal companies to transport and dispose of these materials.

The requirements for the management and disposal of hazardous waste can be found at 40CFR 260-262. The transportation of the materials is regulated by DOT under 49 CFR 170-180. CESQG’s are not required to provide any training under the EPA regulations – 40CFR 260-262 (not true for small or large quantity generators).  However, personnel responsible for the transportation of these materials do require training under the DOT regulations found at 49CFR 172 subpart H.  This training is often overlooked and missed by many CESQG’s.  See the DOT interpretation letter that describes these requirements.

Please contact us with any questions on how these regulations may apply to your operations.

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