Hazardous Waste Training Requirements

SQGs must: ensure that each employee is thoroughly familiar with evacuation signals and routes, and proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations as well as emergencies.

LQGs must maintain a training program for facility personnel as described below:

  • Facility personnel must successfully complete a program of classroom instruction, online training (e.g., computer-based or electronic), or on-the-job training that teaches them to perform their duties in a way that ensures compliance with the Vermont Hazardous Waste Management Regulations.
  • This program must be directed by a person trained in hazardous waste management procedures and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed.
  • At a minimum, the training program must be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment and emergency systems, including, where applicable:
    • Waste handling procedures;
    • Procedures for using, inspecting, repairing and replacing facility emergency and monitoring equipment;
    • Key parameters for automatic waste feed cutoff systems;
    • Communications or alarm systems;
    • Response to fires or explosions;
    • Response to groundwater contamination incidents; and
    • Shutdown of operations.

For facility employees that receive emergency response training pursuant to Occupational Safety and Health Administration regulations 29 CFR 1910.120(p)(8) and 1910.120(q), the large quantity generator is not required to provide separate emergency response training pursuant to this section, provided that the overall facility training meets all the conditions of exemption in this section.

Facility personnel must successfully complete the program required within six months after the date of their employment or assignment to a facility or to a new position at a facility, whichever is later. Employees hired after the effective date of these regulations must not work in unsupervised positions until they have completed the training requirements. At least once each calendar year, facility personnel must take part in a review of the initial training.

The owner or operator must maintain the following documents and records at the facility:

  • The job title for each position at the facility related to hazardous waste management and the name of the employee filling each job;
  • A written job description for each position under which includes the requisite skill, education or other qualifications and duties of personnel assigned to each position;
  • A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position
  • Records that document that the training or job experience required has been given to and completed by facility personnel

Note: Documentation of training is required for at least one employee per satellite accumulation area.

Training records must be kept on current personnel until closure of the facility. Training records on former employees must be kept for at least three years from the date the employee last worked at the facility.

Permitted Hazardous Waste and Used Oil Transporters

Permitted hazardous waste and used oil transporters must provide employee training to all persons who in the course of employment directly affect hazardous waste transportation safety. The training program shall be consistent with DOT employee training requirements of 49 CFR § 172.700. Such training, at a minimum, shall include:

For hazardous waste transporters:

  • DOT's labeling, packing, placarding and shipping requirements as set forth in 49 CFR Parts 171 through 179 and all other applicable DOT regulations;
  •  Familiarity with and use of the most recent edition of the North American Emergency Response Guidebook for hazardous materials published by the DOT;

 For hazardous waste and used oil transporters:

  • Safe vehicle operations to avoid creating hazards to public health, safety, or welfare or the environment; Safe handling of hazardous waste and used oil; and
  • Emergency handling procedures in the event of a release or discharge of hazardous waste or used oil during transportation.

For each person required to be trained, a record of current training inclusive of the preceding three (3) years shall be kept on file by the transporter while these individuals are employed by the transporter, and for 90 days after these individuals cease being employed by the transporter. This period shall be extended automatically for the duration of any unresolved enforcement action, or as ordered by the Secretary.

These records shall include the following:

  • Name of employee;
  • Date of most recent training;
  • Description of training materials;
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Agency of Natural Resources
Department of Environmental Conservation
Waste Management and Prevention Division

Davis Building - 1st Floor
One National Life Drive
Montpelier, VT 05620-3704
802-828-1138