Training Requirements

When creating and maintaining an employee training program, it’s essential to consider which training is required by federal regulations or state laws. We’ve assembled these helpful charts to help guide you through some of the most common training requirements under federal law.

J. J. Keller® Training offers a robust library of training content to help you meet these and other regulatory requirements in workplace safety, transportation, human resources, and other areas. Whether you use our online E-Learning courses, streaming training videos, or both, you’ll know exactly how to maintain compliance with the regulations that apply to you.

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Environmental Training Requirements

Training Topic	Specific Training Required	Training Recordkeeping Required
Risk Management Plan (Program 1 or 2) (40 CFR §68.54)	Before an employee is involved in operating an RMP-covered process and refresher training at least every three years (more often if necessary). Training should address the RMP-covered process and operating procedures that pertain to their duties.	No. Specific training documentation is not required. It is recommended that training be documented to demonstrate compliance with the training requirements.
Risk Management Program (Program 3) (40 CFR §68.71)	Before an employee is involved in operating an RMP-covered process and refresher training at least every three years (more often if necessary). Training should address the RMP-covered process and operating procedures that pertain to their duties.	Yes. The identity of the employee, the date of training, and the means used to verify the employee understood the training. Maintain records for five years.
Ozone Technician Training (40 CFR §82.40)	Before the technician services or repairs any motor vehicle air conditioners; recertification may be required by the regional administrator or state. Training may be on-the-job, training through self-study of instructional material, or on-site training involving instructors, videos, or a hands-on demonstration. Test subject materials is listed in §82.40 (a)(2).	Yes. Technician’s proof of certification, such as certificate or wallet card (kept with technician). Owners of refrigerant recycling equipment must retain records demonstrating that all persons authorized to operate the equipment are certified. Entities that service motor vehicle air conditions must keep records on site. All records must be kept for at least three years.
Ozone Recycling and Emissions Reduction (40 CFR §82.161)	Persons who wish to become Type I, II, III, or Universal technicians must be tested and certified. Recertification may be required by the regional administrator. Apprentices are exempt from certification, but must be supervised by a certified technician. Technicians and organizations certifying technicians that maintain, service, or repair appliances containing class I or class II refrigerants or non-exempt substitute refrigerant.	Yes. Programs certifying technicians must provide technicians with identification cards and maintain records in accordance with section (g) of appendix D to Part 82. Programs certifying technicians must keep a list of all the technicians they have certified and publish this list online. This list must be updated annually. Technicians must keep a copy of their certificate at their place of business. Technicians must maintain a copy of their certificate until three years after no longer operating as a technician.
Spill Prevention, Control, and Countermeasures (SPCC) (40 CFR §82.161)	Oil-handling personnel and designated person who is accountable for discharge prevention and who reports to facility management must be trained in: • The operation and maintenance of equipment to prevent discharges • Discharge procedure protocols • The applicable pollution control laws, rules, and regulations • General facility operations • The contents of the SPCC Plan Discharge prevention briefings must be conducted at least once a year, covering known discharges or failures, malfunctioning components, and any recently developed precautionary measures.	No. Specific training documentation is not required. It is recommended that training be documented to demonstrate compliance with the training requirements.
Facility Response Plans (40 CFR §112.20 - 112.21)	Facilities that, because of their locations, could be reasonably expected to cause significant and substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines must train personnel involved in oil spill response activities. Training must be functional in nature according to job tasks, both supervisory and non-supervisory personnel. Drills and exercises that follow the National Preparedness for Response Exercise Program (PREP) will be deemed satisfactory. Alternative programs are subject to approval by the Regional Administrator. (Recommendation to base the training program on the U.S. Coast Guard’s Training elements for Oil Spill Response.) 40 CFR §112.21 does not specify a training timeframe. However, the USCG at 33 CFR §155 says: • Training should include participation in periodic announced and unannounced exercises; • Training should be conducted periodically to reinforce required knowledge and ensure an adequate degree of preparedness. New employees should complete training prior to being assigned job responsibilities that require participation in emergency responses.	Yes. Logs of discharge prevention meetings, training sessions, and drills/exercises must be kept. These logs may be maintained as an annex to the facility response plan.
Underground Injection Control Permits (Safe Drinking Water Act) (40 CFR §144.51)	Before a permit to operate will be issued, hazardous waste injection well operators must train personnel according to the requirements of 40 CFR §264.16.	Yes. Keep all records used to complete the application for the Safe Drinking Water underground injection control permit for at least three years.
Stormwater Permits – Stormwater Pollution Prevention Plans (SWPPPs) and Best Management Practices (BMPs) (40 CFR §122.26) Multi-Sector General Permit Construction General Permit	Construction site operators on sites that are required to apply for a stormwater permit must develop and train employees on the Stormwater Pollution Prevention Plan. State regulations and stormwater permits often have additional and more stringent SWPPP and training requirements. Members of the stormwater pollution prevention team and anyone working on the site, including construction workers and subcontractors, must be trained. The training should cover SWPPP Best Management Practices (erosion control, good housekeeping, pollution prevention, cleanup measures) specific to the worksite. The training should be conducted before work or employee’s work assignment begins and annually thereafter.	Yes. Records of training must be kept. Training may be included on inspection and maintenance records.
Hazardous Waste Personnel Training — Small Quantity Generators (SQGs) Drinking Water Act) (40 CFR §262.16)	Training is required to be given to all employees who work with or around hazardous waste, including employees who sign the uniform hazardous waste manifest. For SQG the regulations do not specify when initial training must be conducted; however, before the employee works unsupervised is the requirement for larger generators. Training for large quantity generators is required within six months after the employee starts work. Training must include proper waste handling and emergency procedures relevant to the employee’s specific responsibilities during normal facility operations and emergencies.	No. Specific training documentation is not required. It is recommended that training be documented to demonstrate compliance with the training requirements.
Hazardous Waste Personnel Training — Large Quantity Generators (LQGs) (40 CFR §262.17)	Facility personnel who work with or around hazardous waste must receive initial training within six months after the employee starts work or is reassigned to a new position. Employees may not work unsupervised until they have completed their training. Refresher training must be completed annually. Facility- and job-specific training is required and may include classroom instruction, online training, or on-the-job training. Training must cover how to respond to emergencies, emergency procedures, emergency equipment, and emergency systems.	Yes. Training documents must be maintained at the facility. The records must include: the job title for each hazardous waste position at the facility and the name of the employee filling the job, a written job description for each hazardous waste position at the facility, a written description of the type and amount of the introductory and continuing training given to each hazardous waste employee, and records that document the training or job experience given to, or completed by, facility personnel. Training records must be kept until closure of the facility. Records for former employees must be kept for at least three years from the date the employee last worked at the facility.
Hazardous Waste Training — Permitted and Interim Status Treatment, Storage, and Disposal Facilities (40 CFR §264.16 and §265.16)	Facility personnel who work with or around hazardous waste must receive initial training within six months after the employee starts work or is reassigned to a new position. Employees may not work unsupervised until they have completed their training. Refresher training must be completed annually. Facility- and job-specific training is required and may include classroom instruction, online training, or on-the-job training. Training must cover how to respond to emergencies, emergency procedures, emergency equipment, and emergency systems. Training is required to include shutdown operations.	Yes. Training documents must be maintained at the facility. The records must include: the job title for each hazardous waste position at the facility and the name of the employee filling the job, a written job description for each hazardous waste position at the facility, a written description of the type and amount of the introductory and continuing training given to each hazardous waste employee, and records that document the training or job experience given to, or completed by, facility personnel. Training records must be kept until closure of the facility. Records for former employees must be kept for at least three years from the date the employee last worked at the facility.
Universal Waste Training — Small Quantity Handlers (40 CFR §273.16) AND Large quantity handlers (40 CFR §273.36)	Facility personnel who work with or around hazardous waste must receive initial training within six months after the employee starts work or is reassigned to a new position. Employees may not work unsupervised until they have completed their training. Refresher training must be completed annually. Facility- and job-specific training is required and may include classroom instruction, online training, or on-the-job training. Training must cover how to respond to emergencies, emergency procedures, emergency equipment, and emergency systems. Training is required to include shutdown operations.	Yes. Training documents must be maintained at the facility. The records must include: the job title for each hazardous waste position at the facility and the name of the employee filling the job, a written job description for each hazardous waste position at the facility, a written description of the type and amount of the introductory and continuing training given to each hazardous waste employee, and records that document the training or job experience given to, or completed by, facility personnel. Training records must be kept until closure of the facility. Records for former employees must be kept for at least three years from the date the employee last worked at the facility.
Universal Waste Training — Small Quantity Handlers (40 CFR §273.16) AND Large quantity handlers (40 CFR §273.36)	All employees who handle or have responsibility for managing universal waste must be trained on proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility. The frequency of training is not specified.	No. Specific training documentation is not required. It is recommended that training be documented to demonstrate compliance with the training requirements.
Used Oil (40 CFR §279.22)	All used oil generators are subject to the applicable training requirements in the Spill Prevention, Control, and Countermeasures (SPCC) rule in 40 CFR §112. If the used oil is stored in underground storage tanks, the training requirements of 40 CFR §280 may apply. To determine frequency of training, see the SPCC training requirements or the Underground Storage Tank (UST) training requirements.	Yes. See the SPCC or UST training requirements.
Toxic Substances Control Act — Protection in the Workplace (40 CFR §721.63)	Each person who is reasonably likely to be dermally exposed or through inhalation in the work area to a chemical substance identified in §721 Subpart E, must receive training. Also PPE and PPE training that meets 29 CFR §1910.132 and §1910.133 must be provided. The training must be conducted whenever a substance is identified as being subject to §721.63 and employees are dermally exposed or may be exposed by inhalation.	No. Specific training documentation is not required. It is recommended that training be documented to demonstrate compliance with the training requirements.
Toxic Substances Control Act — Hazard Communication Program (40 CFR §721.72)	Employers are required to develop and implement a written hazard communication program for substances identified in Subpart E in the workplace. (The employer may use an existing Hazard Communication Program such as OSHA’s Hazard Communication Program at 29 CFR §1910.1200.) The training must be provided at the time of each employee’s initial assignment to a work area containing the substance and whenever the substance subject to this section is introduced into the employee’s work area for the first time.	No. Specific training documentation is not required. It is recommended that training be documented to demonstrate compliance with the training requirements.
Pesticide Safety Training for Workers Exposed to Pesticides (40 CFR §170.130 and 40 CFR §170.401)	Agricultural workers exposed to pesticides are required to be provided pesticide safety information in a manner they can understand (written materials or oral communication). The presenter must be able to answer workers’ questions. This must be provided: • Before a worker enters a treated area on the agricultural establishment during a restricted-entry interval, or • Before a worker enters any areas on the agricultural establishment where, within the last 30 days an applicable pesticide has been applied or the restricted entry interval for such pesticide has been in effect, or • Before the sixth day of entry.	Yes. An EPA-approved Worker Protection Standard worker training certificate is required to be provided as record of training
Pesticide Safety Training for Handlers (§170.230 and 40 CFR §170.501)	Before any handler performs any handling tasks, general pesticide safety information must be presented to handlers either orally or from written materials or audio-visually. The information must be presented in a manner that the handlers can understand (e.g., through a translator). The presenter must be able to answer handlers’ questions.	Yes. An EPA-approved Worker Protection Standard worker training certificate is required to be provided as record of training.
Asbestos-Containing Materials in Schools (40 CFR §763.92)	All members of a school’s maintenance and custodial staff (custodians, electricians, heating/air conditioning engineers, plumbers, etc.) who may work in a building that contains ACBM (asbestos-containing building materials) must attend awareness training of at least two hours (even if they are not required to work with ACBM). Training must include: • Information on asbestos and its various uses and forms. • Information on the health effects associated with asbestos exposure. • Locations of ACBM identified throughout each school building where the employee works. • Recognition of damage, deterioration, and delamination of ACBM. Additional 14 hours of training for employees who conduct any activities that will disturb ACBM. This training must include hands-on training in the use of PPE and good work practices.	No. Specific training documentation is not required. It is recommended that training be documented to demonstrate compliance with the training requirements.
Asbestos-Abatement (40 CFR §763.122)	At the time of initial assignment and at least annually thereafter, state and local government employees who are not protected by OSHA’s Asbestos Standards at 29 CFR §1910.1001 and 29 CFR §1926.1101.	Yes. Maintain all training records for one year beyond the last date of employment.
Lead Renovation, Repair, and Painting Rule (RRP) (40 CFR §745 Subpart E)	Before working on a lead-based paint abatement project, abatement workers must complete an accredited course and receive a course completion certificate from an EPA accredited training program. Recertification must be completed every three years (if the course includes a hands-on assessment and test) or every five years (if the course includes a proficiency test).	Yes. Training provided to workers must be documented and maintained for a period of three years.
Underground Storage Tanks (UST) (40 CFR §280 Subpart J)	Training requirements are different for Class A, B, and C operators. States may have additional training and testing requirements. Class A and B operators: Within 30 days of assuming duties. Class C operators: Before assuming duties. Retraining must be done within 30 days if a UST operator (Class A, B, or C) is determined to be out of compliance. Retraining is not necessary for Class A and B operators if they complete annual refresher training.	Yes. Owners and operators must maintain a record identifying all currently designated operators at the facility.