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We would like to remind you to perform annual hazardous waste management training and maintain complete records of the training. These are RCRA requirements for all Large Quantity Generators of hazardous waste. The U.S. EPA notes that two of the most common violations by large quantity generators is the lack of annual RCRA training and missing training records.

If you are not sure if you will be a Large Quantity Generator for 2009, I suggest you send us your 2009 hazardous waste manifests to review your status.

Region 5 of the U. S. EPA has been very active in recent years enforcing these requirements. They are inspecting small companies in Illinois, particularly those that perform electroplating or make printed circuit boards. Within the past year, Illinois companies have been fined heavily for failure to complete the training and retain proper records.

Also, additional training is required for Department of Transportation (DOT) Hazardous Materials and Security Awareness. DOT training is required for employees involved in the handling and preparation of hazardous materials for shipment. Not limited to hazardous wastes, also included are certain nonwastes and commercial products that are still considered DOT hazardous materials. Spent copper etchant and lead dross that is shipped as a valuable commodity would be examples of DOT hazardous materials.

Admiral Environmental Services can perform these required training sessions for you. The training would be tailored to your situation, covering only necessary subjects specific to your facility. We can also help you determine if material handled and shipped from your facility would require employees to complete the DOT training.

There are many requirements for Large Quantity Generators, but we want to emphasize this annual requirement partly because of the special EPA enforcement initiative. As always, we can assist your efforts for compliance with all the waste requirements.