RCRA Compliance Training

RCRA Compliance Training

 RCRA training focuses on the Duties of the Emergency Coordinator and the Management of Hazardous Waste as required in the RCRA regulations. 

        This seminar is designed to meet both your
State and Federal requirements for training.
Failure to complete required training is
a fineable violation.

          As most readers already know, HazWaste compliance is a requirement at both the federal and state level.  Too often there exists the mistaken belief that "Regulations" are either not laws or less important than "Statutory" laws.  So let's take a brief visit to the "Courtroom".  Most citizens are aware that the power of a Judge to "punish" for a statutory violation includes "Contempt", "Fine", "Injunction" (both preventative and mandatory), and in severe cases, "Incarceration".  Did you know that each of the above judicial options is also available to any Judge hearing a "Complaint" regarding violation of a state or federal regulation?  And, by the way, while the regulations governing Large Quantity Generators are a bit more severe than those governing Small Quantity Generators, nevertheless each category has the same exposure to lawful compliance obligations.
          Perhaps the most frequently asked question of this "Trainer" is..."Where does it say that I have to take this Annual Training?"  The answer is confusing even to some attorneys; but, can best be summarized as follows: a close reading of 40 CFR 262.34(a)(4), a part of the regulations which appears to deal only with "Accumulation Time", discloses the method by which a generator is allowed to avoid the need to obtain a "Permit" for the storage of hazardous waste.  That "reg" defines the method as compliance with 40 CFR 265.16, which is the actual statement of the Annual Training Requirement.  Yes, it is true that this part of the regulations was originally intended to govern the training requirements of HazWaste disposal facility personnel, but it was made applicable to LQGs and SQGs by the clever language added at the end of 40 CFR 262.34(a)(4).  So next time your "Management" questions your need for training, just show them this brief summary.

Here's what some of our past attendees have said:

"This is the best training manual I've seen in eleven years with D.E.P."

"Recently, we were audited.  There were no NOV's or fines.  The reason the audit went as it did was due to the training I've received at your seminar."

"... the price of 3 admissions to your seminar, weighed against a clean D.E.P. RCRA Inspection Report makes it feel like it was free."

"Thanks again for the inspiring seminar.  You obviously are dedicated to your work."

"... you made an excellent presentation..."

"The RCRA regulations are very serious business and I feel much better knowing that I received training from someone so knowledgeable in the "environmental world".

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