Hazardous Waste Coordinator Training and Certification

Although common to other environmental programs, the training and certification of hazardous waste coordinators is a new concept. This program requires each hazardous waste generator that generates more than 220 pounds of hazardous waste in one month to have on staff at the facility where the hazardous waste is generated, a hazardous waste coordinator (HWC) certified by DES. This certification program is in response to legislation passed in 2002 and took effect in January of 2003 under RSA 147-A: 5, III. DES intends through this program to provide the necessary tools for New Hampshire industries to attain and then maintain compliance under the New Hampshire Hazardous Waste Rules.

Why It Is Needed
Virtually every business produces some form of hazardous waste and has faced various dilemmas in waste identification, storage and disposal. Current DES inspections report high rates of non-compliance with the hazardous waste rules. There are approximately 300 facilities in the state that generate at least 220 pounds of hazardous waste per month. DES strives to teach the best possible management for hazardous waste generated by providing comprehensive training and certification under this program. While attending this training, a HWC may come to realize that their facility is engaging in practices that are not in compliance with the hazardous waste regulations, such as improper handling and labeling of wastes, poor training of employees, and inadequate inspections and documentation. Should this occur, DES expects issues of non-compliance will be addressed by the certified HWC upon return to their facility. These expected changes will be viewed by DES as significant improvements that will provide a safer and healthier environment.

Goal of Program
The goal of the certification program is to empower each HWC to be responsible for ensuring that the generator is aware of applicable requirements relating to hazardous waste management, including but not limited to identification, storage, transportation, and disposal. DES wants to ensure that no business will be out of compliance due to a lack of knowledge of the requirements and is committed to enhancing environmental stewardship in New Hampshire through this new training and certification program.

The HWC training program addresses a wide range of issues associated with the management of hazardous waste. This training provides the opportunity for open discussion about common hazardous waste management problems facilitating solutions through professional cooperation. Training includes:

• Hazardous waste determination
• DES classification and notification requirements
• Hazardous waste accumulation rules for storage, packaging and labeling
• Manifest and quarterly reporting requirements
• Inspection and compliance regulations such as personnel training
• Requirements for incompatible wastes
• Review of preparedness and prevention requirements and contingency plan requirements
• Permitting requirements - with emphasis on limited permits
• Universal wastes, used oil recycling requirements and pollution prevention
• Updates on rule changes pertaining to hazardous waste

State Certification
This first-in-the-nation certification program for HWCs is being implemented to provide a forum for educating generators in the complex regulatory area of hazardous waste management. Initial certification will provide the HWC with the regulatory nuts and bolts to assure the generator's compliance under the Hazardous Waste Rules. This certification will meet the training requirement in Env-Wm 509.02(a)(2), which incorporates 40 CFR 265.16 (RCRA training). Future certification courses will be designed to encourage generators to move "beyond compliance," by developing resource conservation, waste minimization, and recycling programs at their facilities.

In the first year of the program, HWCs can expect a basic one-day certification workshop with a comprehensive written exam, which will cover elements required of New Hampshire hazardous waste generators. In subsequent years, the HWC may apply for annual recertification by attending specific comprehensive workshops designed to provide more in-depth training.

Application and Renewal Procedures
Every generator meeting the 220-pound requirement will need to send at least one HWC from each facility to an initial certification course. Each HWC will be required to attend the one-day training course conducted by DES and pass a comprehensive exam. Upon successful completion of the course and the exam, certification will be issued for one year. Each year following the initial certification, the HWC will be required to apply for recertification and attend continuing education course(s) to renew their certification. The training schedule will be posted on the DES website. A non-refundable fee of $125, and an additional course fee are required for all initial and renewal applications.

For more information, contact Tim Prospert, Hazardous Waste Certification manager, at tprospert@des.state.nh.us; (603) 271-7837; or NH Department of Environmental Services - Waste Management Division, PO Box 95, Concord, NH 03302-0095.