HAZWOPER guide · 2 min read · Updated 2026-11-03
RCRA Hazardous Waste Training Requirements by Generator Category
The Resource Conservation and Recovery Act (RCRA) regulates hazardous waste from "cradle to grave." EPA's training requirements depend on how much hazardous waste a site generates each month. RCRA training is a separate requirement from OSHA HAZWOPER, though many facilities need both.
Generator categories
| Category | Hazardous waste per calendar month | On-site accumulation |
|---|---|---|
| Very small quantity generator (VSQG) | ≤ 100 kg (and ≤ 1 kg acute) | No time limit; up to 1,000 kg |
| Small quantity generator (SQG) | > 100 kg and < 1,000 kg | Up to 180 days (270 if TSDF is over 200 miles away); max 6,000 kg |
| Large quantity generator (LQG) | ≥ 1,000 kg, or > 1 kg acute | Up to 90 days |
Categories come from 40 CFR 262.13, updated by EPA's 2016 Hazardous Waste Generator Improvements Rule. States may be stricter.
Training by category
- LQGs (40 CFR 262.17(a)(7)): a formal personnel training program, classroom or on-the-job, teaching hazardous waste management procedures and emergency response relevant to each person's job. New employees must finish within six months and may not work unsupervised until trained. Everyone takes an annual review. Records: job titles, descriptions, training content and completion, kept until closure for current employees and 3 years for former employees.
- SQGs (262.16(b)(9)(iii)): ensure all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their duties.
- VSQGs: no specific training requirement, though basic training is good practice.
- TSDFs (264.16 / 265.16): formal training like LQGs, and employees also fall under HAZWOPER 1910.120(p).
Courses: RCRA Hazardous Waste Generator Training and the annual RCRA Hazardous Waste Generator Refresher Training.
Satellite accumulation areas
Generators can collect up to 55 gallons of non-acute hazardous waste, or 1 quart of liquid or 1 kg of solid acute hazardous waste, at or near the point of generation and under the control of the operator (40 CFR 262.15). Containers must be closed, in good condition, compatible with the waste and marked "Hazardous Waste" with an indication of the hazards. See Hazardous Waste Satellite Accumulation Area Training.
Manifests and DOT training
Off-site shipments travel on the Uniform Hazardous Waste Manifest (EPA Form 8700-22), now handled through EPA's e-Manifest system. Anyone who signs a manifest or prepares a hazardous materials shipment is a DOT hazmat employee and needs training under 49 CFR 172.704 at least every 3 years. See Hazardous Waste Manifest Training and EPA RCRA/DOT Combined Hazardous Materials Compliance Training.
Universal waste
Batteries, pesticides, mercury-containing equipment, lamps and aerosol cans can be managed under the simpler universal waste rules at 40 CFR 273. Handlers must tell employees about proper handling and emergency procedures. See RCRA Universal Waste Handler Training.
Contingency plans and emergency coordinators
LQGs and TSDFs need a written contingency plan and an emergency coordinator on site or on call at all times. SQGs need a designated emergency coordinator and posted emergency information. See Hazardous Waste Contingency Plan and Emergency Coordinator Training.
Frequently asked questions
Is RCRA training the same as HAZWOPER?
No. RCRA training is an EPA requirement for hazardous waste generators and TSDFs. HAZWOPER is an OSHA worker safety standard. TSDF employees and some generator employees need both.
How often is RCRA training required?
Large quantity generators and TSDFs must provide an annual review of initial training. New employees must be trained within six months.
What are the RCRA generator categories?
Very small quantity generators (100 kg or less per month), small quantity generators (more than 100 kg and less than 1,000 kg) and large quantity generators (1,000 kg or more, or more than 1 kg of acute hazardous waste).
This guide summarizes federal OSHA, Cal/OSHA and EPA rules for training purposes. It is not legal advice. Always check the current regulation text and your site safety and health plan.