Which industries require hazardous waste training?
Many industries generate hazardous waste. If you belong in one of these fields, you must train your workers in handling such wastes to ensure their safety and protect the environment. Different agencies regulate hazardous waste, such as the Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), and Department of Transportation (DOT). Title 40 of the Code of Federal Regulations (CFR) discusses the federal hazardous waste regulations.
Requirements generally depend on your monthly waste generation. Some states have not adopted certain federal regulations, while others have their own standards. You need to identify which regulations apply to you, since some state requirements may be more stringent. To give you a good overview, Hazmat School explains which industries have hazardous waste training requirements.
Key Takeaways
Hazardous waste training requirements protect workers and the environment. Here’s what you need to know about these guidelines:
- Industries that handle hazardous wastes must undergo appropriate training, which typically includes companies in the manufacturing, oil, waste management, health care, transportation, emergency response, and construction industries.
- Navigating compliance requirements involves knowing how much hazardous waste you generate monthly and the types you produce.
- All workers involved in the process, whether they’re managing, transporting, cleaning, or treating hazardous wastes, must receive the training from their employers, hazmat employees, or contracted training services.
Agencies That Govern Hazardous Waste Regulations
Different agencies and organizations have standards and requirements for managing hazardous waste, including:
- EPA: The Resource Conservation and Recovery Act (RCRA) enables the EPA to control hazardous waste management, including generation, transportation, treatment, storage, and disposal.
- OSHA: OSHA ensures worker safety and health protection through different standards. For instance, OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) contains the requirements for workplaces that can potentially release hazardous materials. The Hazard Communication Standard requires the classification of hazardous chemicals and informing workers of this classification. Meanwhile, workplaces that involve asbestos — except for construction and ship-related employment — must follow standards for toxic and hazardous substances.
- DOT: The DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) establishes standards for companies involved in the hazardous materials transportation system, such as those that manufacture packaging materials to be used in transporting hazardous materials.
Noncompliance with relevant regulations can lead to penalties. For instance, violating PHMSA’s federal hazardous material transportation law can lead to penalties ranging from $102,348 to $238,809 per violation. You can be charged the maximum violation if noncompliance results in a severe injury, serious illness, or death. Training violations can cost a minimum of $617 per violation.
Industries With Hazardous Waste Training Requirements
Workers who handle hazardous waste must undergo hazardous waste training. These individuals generally work in the following industries:
1. Manufacturing and Chemical
The manufacturing and chemical industries produce, store, and use hazardous materials, such as chemicals and gases. Improper material handling can lead to fires, explosions, and dangerous chemical reactions. HAZWOPER standards, or 29 CFR 1910.120, apply to the general industry, which includes all industries except for construction, agriculture, and maritime. Relevant training courses often teach you how to:
- Communicate hazards.
- Interpret safety data sheets.
- Wear proper personal protective equipment.
Workers who operate chemical-handling machinery or those responsible for decontamination and emergency response must undergo such training.
2. Oil, Gas, and Energy
The oil, gas, and energy industries often deal with petroleum products, flammable gases, and other radioactive substances. Wastes from crude oil and natural gas operations are generally subject to the RCRA and state regulations. Industry operations often involve transporting oil and gas through pipelines, which pose risks of leaks and spills. Meanwhile, nuclear energy plants often deal with radioactive materials. Proper training enables workers to handle and dispose of these hazardous materials safely and mitigate risks.
3. Waste Management and Environmental Services
Workers who manage industrial waste and clean up environmental disasters require training for handling hazardous materials. Chemical spills and similar contamination events involve removing and cleaning up hazardous substances. The training is essential so workers can properly dispose of materials that pose health and environmental risks. For instance, these materials can include electronics, chemicals, or biohazardous waste.
4. Pharmaceutical and Other Health Care Industries
Pharmaceutical and other health care industries often deal with medications, chemicals, and other medical waste, which are biohazardous materials. Medical and research laboratories, in particular, work with pathogens, radioactive materials, and other dangerous substances, which, when mishandled, can cause contamination, health risks, and legal issues. Proper worker training ensures health care professionals can manage waste responsibly.
5. Transportation and Logistics
Companies in the transportation and logistics industries move hazardous materials across locations. While they don’t generate waste per se, they’re involved in waste handling as a part of a chain. For instance, a trucking company may transport hazardous wastes between states. Workers must understand proper packaging, labeling, and transportation requirements to adhere to relevant regulations.
Your workers need a certification or endorsement depending on your industry. Truck drivers who transport hazardous materials, such as corrosive substances and flammable materials, need a hazmat endorsement on their commercial driver’s license. Airline workers must follow the International Air Transport Association (IATA) regulations, while maritime workers must meet the International Maritime Dangerous Goods (IMDG) regulations. Medical couriers must also be highly trained in moving time-sensitive, temperature-controlled cargo and comply with regulations such as OSHA’s standards for bloodborne pathogens.
6. Emergency Response and Public Safety
Emergency responders are often the first to respond in hazardous situations, whether there’s a gas leak, a chemical spill, or a factory fire. Specialized teams must understand how to handle hazardous materials, especially when performing decontamination processes or containment procedures. Some emergency responders may not handle waste themselves, but are still involved in dealing with hazardous situations. For instance, paramedics might need to manage patients who were exposed to dangerous substances.
Crime scene cleanup industries must also learn to sanitize areas that were used for criminal activities. These areas may contain hazardous wastes, especially if they were used for murder or drug production. Proper training ensures workers understand how to manage blood, bodily fluids, and other potentially harmful substances.
7. Construction and Demolition
Construction and demolition workers often encounter hazardous wastes on-site, especially in older buildings with asbestos and lead-based paints. Exposure to these wastes can cause long-term health issues, such as lead poisoning or lung cancer. Proper training helps workers identify these hazardous materials and understand how to remove them safely.
OSHA has a specific HAZWOPER standard for the construction industry known as 29 CFR 1926.65. Employers must provide relevant training for their workers who can become exposed to hazardous materials during:
- Government cleanup operations.
- Corrective actions involving cleanup operations at RCRA-covered sites.
- Voluntary cleanup operations at uncontrolled hazardous waste sites.
How to Navigate Compliance Requirements
Having a systematic approach can help you navigate industry-specific compliance requirements regarding hazardous waste management. Consider these steps:
1. Identify if Your Facility Generates Hazardous Waste
Wastes pertain to solid, liquid, or contained gaseous materials you discard through disposal, burning, incineration, or recycling. They are often by-products of a manufacturing process or a commercial product your business has used. These wastes can be hazardous and can be considered:
- Listed waste: A listed waste is a hazardous waste type listed in Title 40 of the CFR. Acute hazardous wastes are the most dangerous types, which are fatal to humans even in low doses.
- Characteristic waste: Characteristic wastes can be ignitable, corrosive, reactive, or toxic. An ignitable waste catches fire, while corrosive wastes corrode metals or come with high or low pH. Reactive wastes are unstable and can explode or produce toxic fumes. Toxic wastes are fatal when absorbed or ingested, and leach toxic chemicals into the soil or groundwater. You can determine toxic waste through the Toxicity Characteristic Leaching Procedure.
2. Calculate How Much Hazardous Waste You Generate Monthly
Companies that generate hazardous waste are called generators, and the amount of waste you produce determines your generator category. Hazardous wastes are often liquids, which you measure in gallons. You must convert gallons to kilograms or pounds to count the wastes.
The EPA has three generator categories, each with its own hazardous waste requirements:
- Very small quantity generator (VSQG): Companies that generate less than 100 kg of hazardous waste per month.
- Small quantity generator (SQG): Companies that generate 100-1,000 kg of hazardous waste per month.
- Large quantity generator (LQG): Companies that generate more than 1,000 kg of hazardous waste per month.
Sometimes, you might produce larger amounts of hazardous waste than your typical operations — for instance, due to a cleanout or an oil spill. This event might move you from a VSQG to an SQG. Because it’s an uncommon circumstance, you can be eligible for a different set of requirements to avoid having to comply with more stringent generator regulations.
3. Notify Relevant Authorities of Your Hazardous Waste
If you’re an SQG or LQG, you must notify the EPA or state agencies of your hazardous waste activities. Some states also have the same requirements for VSQGs.
4. Manage Wastes Appropriately
You need to manage your hazardous waste according to the generator category requirements. Certain waste types may also have unique requirements, including:
- Universal wastes, such as batteries, pesticides, and mercury-containing equipment.
- Hazardous wastes at academic laboratories.
- Pharmaceutical hazardous wastes.
5. Transport Wastes Properly
SQGs and LQGs are often required to have a manifest to transport hazardous waste off-site. These forms enable the tracking of hazardous wastes from your generator facility to a waste management facility that will store, treat, and dispose of the wastes.
6. Recycle, Treat, and Dispose of Wastes Correctly
SQGs and LQGs can generally recycle hazardous wastes on-site without permits, provided they comply with waste accumulation time limits and regulations under Title 40 of the CFR. You may also treat hazardous waste on-site in an accumulation unit, such as a tank or container, without a permit, to transform the waste into a nonhazardous or less hazardous waste — provided the treatment is nonthermal and you comply with the other requirements in Title 40.
Otherwise, you must treat and dispose of the wastes according to the Hazardous Waste Treatment, Storage, and Disposal Facilities regulations.
Frequently Asked Questions
To further understand what’s required of your industry, consider these common questions regarding hazardous waste management training:
Who Is Required to Have Hazardous Waste Training?
All employees who handle or are exposed to hazardous wastes must undergo appropriate training. This requirement includes employees involved in the generation, management, transportation, treatment, storage, and disposal of hazardous wastes.
Is Hazmat Training Required by Law?
Yes, hazmat training is required by law. The training must include the following topics:
- General hazardous waste or material requirements
- Training specific to the employee’s work
- Safety training
- Security awareness training
If you’re required to have a security plan, security training must be in-depth. This training can be performed by employers, hazmat employees, or contracted training services.
What Specific Hazardous Waste Courses Are Required for the Construction Industry?
The construction industry would benefit from hazardous waste courses discussing standards unique to the industry. For instance, OSHA has the HAZWOPER standard, or 29 CFR 1926.65, for the construction industry, which is similar to 29 CFR 1910.120, a more general standard of the same title. These standards apply to operations involving an ongoing or a likely incident of an uncontrolled release of hazardous substances.
Consider courses with discussions unique to your business type. For instance, you may choose a course that covers forklift and industrial truck safety, scaffolding requirements, or asbestos management.
How Much Does Hazardous Waste Training Cost for a Small Business?
Training costs depend on the specific course. For instance, a DOT or RCRA training course can cost around $150 to $300. Some training courses may charge per participant. Participants can often work at their own pace and receive their certificate immediately after completion.
Hazardous Waste Training Is Essential for Compliance
When handling dangerous and toxic materials, workers in many industries are required to undergo hazardous waste training to protect themselves and the environment. Generally, these industries include:
- Manufacturing and chemical.
- Oil, gas, and energy.
- Waste management and environmental services.
- Pharmaceutical and other health care industries.
- Transportation and logistics.
- Emergency response services and public safety.
- Construction and demolition.
To effectively navigate the compliance requirements, identify whether you produce or manage hazardous waste materials, and which waste type you’re handling. Then, calculate your monthly waste production. You must also notify relevant authorities, such as the EPA or state agencies, of your hazardous waste activities. Manage, transport, and treat the waste appropriately based on the industry- and waste-specific requirements.
This story was produced by Hazmat School and reviewed and distributed by Stacker.
