EPA Training Requirements

The Environmental Protection Agency (EPA) administers the rules and regulations that protect, preserve, and clean up the air, waterways, and land of the United States. If you generate, transport, treat, store, or dispose of hazardous waste you will also need to be in compliance with federal EPA regulations.

To make sure you are in compliance with EPA's rules, the Environmental Protection Agency delegates much of the responsibility to its regional offices. There are 10 EPA regions and every state has been assigned to a specific EPA region.


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EPA training requirements focus on workplace activities designed to eliminate the release of pollutants and wastes into the environment, both on-site and off-site. This includes asbestos, lead abatement, and certain other highly toxic or cancer-causing materials.

Topic Training Refresher Training Trainer Qualifications
Air-Ozone Depleting Substances
40 CFR 82.40
Motor vehicle air conditioning service technicians:
Training and certification that covers the topics described in the regulation
   
Asbestos Abatement
Certification
{40 CFR 763 Subpart E, Appendix C
See the national section ASBESTOS.
Workers:
4-day course with at least 14 hours hands-on training
Annually: 1 full day  
Contractors/supervisors:
5-day course with at least 14 hours hands-on training
Annually: 1 full day  
Inspectors:
3-day course with at least 4 hours hands-on training
Annually: 1/2 day  
Planners:
2-day management planner course and 3-day inspector course
Annually: 1/2 day for management planner and 1/2 day for inspector  
Project designers:
3-day course
Annually: 1 full day  
Asbestos Abatement
Demolition and Renovation
40 CFR 61.145
Foremen/management level personnel:
Applicability, notifications, material identification, control procedures, waste disposal, recordkeeping, reporting, hazards, and worker protection
Every 2 years  
Asbestos Abatement
Schools
40 CFR 763.92
Maintenance and custodial staff:
2 hours of awareness training within 60 days of commencement of employment
   
Employees who perform activities that disturb ACBM:
2 hours of awareness training plus 14 hours of activity training including hands-on use of PPE and good work practices
   
Boilers and Industrial Furnaces
40 CFR 63.1206 and 40 CFR 261.38
Personnel whose activities may reasonably be expected to directly affect hazardous air pollutant emissions:
Training of a technical level commensurate with the person's job duties, as specified in the training manual. Personnel receiving training must pass an examination at the end of the training program.
Annually  
Control room operators:
Training and certification through a site-specific, source-implemented program that includes an examination and covers the topics described in the regulation, or training and certification under one of the American Society of Mechanical Engineers standards described in the regulation, or training and certification under a state program
 
Units firing emissions-comparable fuel:
Boiler operators must be trained in procedures relevant to the positions in which they are employed, including the topics described in the regulation.
 
Hazard Communication Standard
40 CFR 721.72
See the national section HAZARD COMMUNICATION STANDARD.
Affected employees:
At the time affected employees enter a work area where a significant new use of a chemical substance has been introduced
   
Hazardous Waste TSDFs
40 CFR 264.16 and 40 CFR 265.16
TSDF personnel:
Within 6 months of commencement of employment, or assignment to a new position at the facility (whichever is later), classroom instruction or on-the-job training relevant to the individual’s job and including emergency procedures, equipment and systems; HAZWOPER training suffices if it meets all the RCRA emergency response training requirements.
When transporting waste off-site or receiving waste, see the training requirements for DOT Hazardous Materials Employees.
Annually The person conducting the training must be trained in hazardous waste management procedures.
Hazardous Waste Remediation Waste Management Sites (RWMS)
40 CFR 264.1(j)
RWMS personnel:
Classroom or on-the-job training on how to respond effectively to emergencies and on how to perform their duties in a way that ensures the RWMS complies with the hazardous waste TSDF requirements that also apply to an RWMS. The training requirements of 40 CFR 264.16 are not applicable unless the RWMS is also subject to a traditional RCRA permit.
   
Hazardous Waste LQGs
40 CFR 262.34(a)(4) and 40 CFR 265.16
Same training requirements as TSDF personnel
When transporting waste off-site, see the training requirements for DOT Hazardous Materials Employees.
  Same as for hazardous waste TSDFs
Hazardous Waste SQGs
40 CFR 262.34(d)
Ensure facility personnel are thoroughly familiar with proper waste-handling procedures and emergency response procedures relevant to their responsibilities
When transporting waste off-site, see the training requirements for DOT Hazardous Materials Employees.
   
Hazardous Waste Generators – Academic Laboratory Personnel
40 CFR 262.207 See the national section GENERATORS.
Training to all individuals working in a laboratory at the eligible academic entity. Training for laboratory workers and students must be commensurate with their duties so they understand the requirements of the Academic Laboratory Rule and can implement them.

Training methods can include: formal classroom training, electronic/written training, and on-the-job training.

Certain labs in New England have more stringent requirements under the University Laboratories Project XL (40 CFR 262.105).
   
Hazardous Waste – Low Level Mixed Waste (LLMW)
40 CFR 266.230
The training of personnel who manage stored conditionally exempt LLMW must ensure that the conditionally exempt waste is safely managed and include training in chemical waste management and hazardous materials incidents response that meets the personnel training standards of 40 CFR 265.16(a)(3).    
Lead-based Paint Abatement
40 CFR 745.225 and 40 CFR 745.226
See the national section LEAD.
Inspectors:
24-hour course with at least 8 hours of hands-on training
Every 3 years as follows if training course with a course test with hands-on assessment was completed:
  • Inspectors: 8 hours
  • Risk assessors: 8 hours
  • Supervisors: 8 hours
  • Project designers: 4 hours
  • Workers: 8 hours
  • Renovators: 4 hours
  • Dust sampling technician: 4 hours

Every 5 years as follows if training course with a proficiency test was completed:
  • Inspectors: 8 hours
  • Risk assessors: 8 hours
  • Supervisors: 8 hours
  • Project designers: 4 hours
  • Workers: 8 hours
  • Renovators: 4 hours
  • Dust sampling technician: 4 hours
The training program manager must have:
  • At least 2 years’ experience, education, or training in teaching workers or adults;
  • A bachelor’s or graduate degree in building construction technology, engineering, industrial hygiene, safety, public health, education, business administration or program management or a related field; or
  • 2 years of experience in managing a training program specializing in environmental hazards; and
  • Demonstrated experience, education, or training in the construction industry, including lead or asbestos abatement, painting, carpentry, renovation, remodeling, occupational safety and health or industrial hygiene

The qualified principal instructor for each course must have:
  • Demonstrated experience, education, or training in teaching workers or adults;
  • Successfully completed at least 16 hours of any EPA-accredited or EPA-authorized state- or tribal-accredited lead-specific training; and
  • Demonstrated experience, education, or training in lead or asbestos abatement, painting, carpentry, renovation, remodeling, occupational safety and health or industrial hygiene.
Risk assessors:
16-hour course with at least 4 hours of hands-on training; various levels of work experience required ranging from high school diploma and 3 years' work experience to certification as an industrial hygienist, professional engineer, registered architect and/or related certification in engineering/health/environmental field
Supervisors:
32-hour course with at least 8 hours of hands-on training; 1 year's experience as a certified LBP abatement worker or 2 years in a related field or in the building trades
Project designers:
8-hour course and either a minimum of 4 years' experience in building construction and design or related field, or bachelor's degree in engineering, architecture, or a related profession and 1 year's experience in building construction and design or a related field
Abatement workers:
16-hour course with 8 hours of hands-on training
Renovator:
8-hour course with at least 2 hours of hands-on training
Dust sampling technician:
8-hour course with at least 2 hours of hands-on training
Medical Waste Incinerators
40 CFR 60.34e, 40 CFR 60.53c, and 40 CFR 62.14421 to 62.14423
Incinerator operators:
24-hour operator training course through a state-approved program or an EPA-administered training course
Annual 4-hour course The operator must complete a training course that satisfies the requirements in 40 CFR 62.14422; and must have either 6 months’ experience as an HMIWI operator, 6 months’ experience as a direct supervisor of an HMIWI operator, or completion of at least two burn cycles under the observation and supervision of two qualified HMIWI operators.
SPCC Facilities
40 CFR 112.7, 40 CFR 112.21, and 40 CFR 112 Appendix F
Oil handling personnel:
Instruction in the operation and maintenance of equipment to prevent the discharge of oil; functional training according to job tasks for managers and workers
Annual discharge prevention briefings  
Personnel at facilities required to have FRPs:
Training specific in nature and scope to the responsibilities of oil-handling personnel identified in the FRP; drills and exercises including announced and unannounced tabletop and deployment and participation in larger area drills and exercises
 
Pesticides
40 CFR 170.130, 40 CFR 170.230, 40 CFR 171.4, and 40 CFR 171.5
Agricultural workers:
Training before working with any pesticide product in the production of agricultural plants; should be presented in a way that workers can understand
Every 5 years counting from the end of the month in which the training was completed The person conducting the training must meet at least one of the following criteria:
  • Be currently certified as an applicator of restricted-use pesticides under 40 CFR 171;
  • Be currently designated as a trainer of certified applicators or pesticide handlers by a state, federal, or tribal agency; or
  • Have completed a pesticide safety train-the-trainer program approved by a state, federal, or tribal agency.
Agricultural handlers;
training before performing and handling task; should be presented orally from prepared material or using audiovisual media and in a manner that the handler can understand
Every 5 years counting from the end of the month in which the training was completed  
Certified commercial applicators:
Demonstrated practical knowledge of principles and practices of pest control and safe use of pesticides
 
Certified private applicators:
Demonstrated practical knowledge of pest problems and pest control practices associated with applicable agricultural operations, proper storage, use, handling, and disposal of pesticides and containers
 
RMP
40 CFR 68.54 and 40 CFR 68.71
Program 2 prevention employees:
Training to perform the safety procedures for operation responsibilities
Initial process: Training in process hazards and standard operating procedures as they apply to the specific job
Maintenance: Training in hazards, avoiding/correcting unsafe conditions, and job procedures for maintaining the ongoing mechanical integrity of the process
Change in process: Training for employees involved in operating a process and for maintenance and contract employees whose job tasks will be affected by a change in process before startup
Temporary process: Training in written operating procedures before operation is put in place
Emergency response: Training for employees who will respond to releases of regulated substances in facilities that choose to establish and maintain on-site emergency response capabilities
At least every 3 years  
Program 3 prevention employees:
Initial: Training in operating a process, including overview of the process and operating procedures, specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's task
Maintenance: Required for employees involved in maintaining the ongoing integrity of process equipment, including overview of the process and its hazards, and procedures applicable to employee's job tasks
Contract: Training to ensure that contract employees are trained in the work practices necessary to safely perform his or her job
 
Solid Waste Combustors
40 CFR 60.54b, 40 CFR 60.1155 to 60.1180, and 40 CFR 60.2905.
Small municipal waste combustors (>35 but ≤250 tons per day):
Plant-specific training on the facility's operating manual before assuming responsibilities for operators, shift supervisors, control room operators, ash handlers, maintenance personnel, and crane/load handlers.

EPA or state-approved municipal waste combustor operator training necessary for certification for chief facility operators, shift supervisors, and control room operators.
Annually  
Large municipal waste combustors (>250 tons per day):
Training on the facility's operating manual before assuming responsibilities for operators, shift supervisors, control room operators, ash handlers, maintenance personnel, and crane/load handlers.

EPA or state-approved municipal waste combustor operator training necessary for certification for chief facility operators, shift supervisors, and control room operators.
 
Other municipal waste combustors:
Training and qualifications obtained through a state-approved program or by completing a training course that contains an exam designed and administrated by the course instructor, and a written reference manual that covers all the material in the training course
 
Municipal Solid Waste Landfill Personnel
40 CFR 258.20
Training to detect hazardous waste and PCBs    
Residential, Commercial, and Institutional Solid Waste Collectors
40 CFR 243.201-2
Training in safe container and waste-handling techniques and the proper and safe operation of collection equipment    
Stormwater
40 CFR 122.26, 40 CFR 122.34, and 73 FR 56572
Construction site operators at industrial facilities operating under a NPDES individual permit:
Training in the best management practices to reduce runoff to municipal stormwater systems
   
MS4 personnel:
Training in to prevent or reduce pollutant runoff from municipal operations including park and open space maintenance, fleet and building maintenance, new construction and land disturbances, and stormwater system maintenance
 
Personnel identified in a multi-sector general permit facility's SWPPP:
Training in the components of the SWPPP, including spill response procedures, good housekeeping, and material management practices
Annually in some cases  
Underground Injection Wells
40 CFR 144.14
For wells injecting hazardous waste:
Training in facility compliance with underground injection requirements, facility personnel hazardous waste management procedures (including contingency plan implementation), and emergency procedures, equipment, and systems.
Annual review of initial training This program must be directed by a person trained in hazardous waste management procedures.
UST
42 USC 6991i and 40 CFR 280.20
Installer:
Must be certified by the tank and piping manufacturer or licensed by the state implementing agency.
   
Operator:
Must meet state training requirements that are at least as strict as federal EPA guidelines for operator training.
Whenever the tank for which the operator has primary daily on-site management responsibilities is out of compliance with UST requirements  
Universal Waste Handlers
40 CFR 273.16 and 40 CFR 273.36
Small quantity handler (<5,000 kg of accumulated waste at any one time) personnel:
Informed of proper handling and emergency procedures appropriate to the type of universal waste handled at the facility
   
Large quantity handler (5,000 kg or more of accumulated waste at any one time) personnel:
Thoroughly familiar with proper waste handling and emergency procedures relative to individual responsibilities during normal facility operations and emergencies
 

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