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October 29, 2014
Hazwaste Generator Emergency Preparedness
By Elizabeth M Dickinson, JD, Senior Legal Editor - EHS

Under RCRA’s EPA rules, both large quantity generators of hazardous waste (LQGs ) and small quantity generators of hazardous waste (SQGs) must comply with emergency preparedness and prevention procedures relating to response equipment and personnel in the event of a fire, explosion, or release that could threaten human health or the environment. Hazwaste generators must minimize the possibility of such emergencies by (40 CFR 265.32 to 265.37):

alarm
  • Maintaining an internal alarm system, telephone, or two-way radio to call emergency authorities; fire control equipment, and adequate water volume and pressure.
  • Regularly testing and maintaining equipment to ensure proper operation.
  • Ensuring access to internal alarms or emergency communication devices; if only one employee, ensuring immediate access to a telephone or two-way radio capable of summoning emergency assistance.
  • Maintaining required aisle space to allow the unobstructed movement of personnel, fire protection equipment, and spill control equipment during an emergency.
  • Arranging emergency response procedures with local authorities, appropriate for the type of waste handled at the facility.

LQGs

Contingency plan

A “contingency plan” is the RCRA-required written document describing how hazwaste LQGs will respond to an emergency at their facility. It establishes the procedures to be taken to minimize hazards to human health and the environment caused by explosions, fires, or unplanned sudden or nonsudden releases of hazardous waste or constituents to the air, soil, or surface water. The plan must identify the person in charge of its implementation in the event of an emergency (40 CFR 265.50 to 265.56).

Personnel Training

LQGs must follow the same personnel training requirements that apply to hazardous waste TSDFs (40 CFR 262.34(a)(4)). The rules require LQG personnel to complete a program of classroom instruction or on-the-job training designed to ensure the facility’s compliance with EPA regulations. Instruction must be given by someone trained in hazardous waste management procedures; be relevant to the individual jobs at the facility; and familiarize employees with emergency procedures, equipment, and systems (40 CFR 265.16).

SQGs

Although SQGs do not have to prepare a contingency plan, they must have at all times at least one employee (called the emergency coordinator) with responsibility for responding to any emergencies that arise. This employee must either be on the premises or on call and must coordinate the emergency response measures described in 40 CFR 262.34(d)(5).

Additional non-RCRA requirements

Preparedness and prevention requirements other than those described here may apply to generators, including certain Hazardous Waste Operations and Emergency Response (HAZWOPER) regulations and other emergency response requirements overseen by the Department of Labor’s Occupational Safety and Health Administration (OSHA). In addition, the community right to know regulations of the Emergency Planning and Community Right to Know Act (EPCRA) that apply to facilities that manufacture, use or store hazardous chemicals may also apply. 

EPA guidance documents that you may find helpful:
Emergency Equipment List
Managing Your Hazardous Waste: A Guide for Small Businesses
Comprehensive Training Checklist
Integrated Contingency Plan (ICP) Guidance from EPA Region 5

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