Florida Q&A Board
Rob's Question: Is documented RCRA training required for individuals in Florida? (2/5/21)
Kyle N.'s Answer (2/27/21): https://floridadep.gov/waste/permitting-compliance-assistance/content/hazardous-waste-compliance-and-enforcement
Linda M.'s Answer (2/27/21): Yes. Florida's RCRA training rules are the same as the Federal RCRA rules. RCRA facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance with the requirements of their duties at the facility.
The owner/operator must ensure that this program includes the following elements of recordkeeping and training:
1) The job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job;
2) A written job description for each position includes the skill, education, or other qualifications, and duties of facility personnel assigned to each position;
3) A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position;
4) Records that document that the training or job experience required has been given to, and completed by, facility personnel. 5) Training records on current personnel must be kept until closure of the facility.
Training records on former employees must be kept for at least three years from the date the employee last worked at the facility.
McKell S.'s Answer (2/27/21): As mentioned by Linda M. RCRA training is required. The State of Florida has adopted the Federal standards for most of it's RCRA requirements. The State specifically spells out that for Small Quantity Generators (SQG's) Training is required, and for Large Quantity Generators (LQG's) they go a step further and reference the required training. They don't specifically mention training for VSQG, but since training is covered in the Federal Standard, the safe bet is that is required there as well. Linda M's answer explains it very well.