If you’re a hazardous waste generator, you know the consequences of proper storage and disposal violations, and how they can be costly to your bottom line.
Bureaucratic red tape can be frustrating for any business, but state and federal regulations are put into place to protect the environment and health of the public. Following hazardous waste laws is imperative for the safety of your employees and the community as a whole.
Yet, one of the most frequent violations issued occurs when a company does not follow hazardous waste label requirements.
Cutting corners in an effort to save money may end up costing you more in the long run in fines, and maybe even your business depending on the severity of the violation.
If you are a hazardous waste generator who accumulates hazardous waste onsite in containers, you must follow the regulations set forth by the Resource Conservation and Recovery Act (RCRA). These regulations include proper labeling, marking and placarding requirements for hazardous waste containers.
Below we’ll explore what these regulations entail to help you properly mark and label your hazardous waste containers.
California DTSC Guidelines
The California Department of Toxic Substances Control (DTSC) provides its own set of requirements that hazardous waste generators must follow when it comes to proper labeling.
- The date upon which each period of accumulation begins must be clearly marked and visible for inspection on each accumulation unit.
- While being accumulated on site, each generator tank or container must be labeled or clearly marked with the words, “Hazardous Waste.”
- Each container and portable tank in which hazardous waste is accumulated must be labeled with the following information:
- Composition and physical state of the waste
- Statement or statements that call attention to the particular hazardous properties of the waste
- Name and address of the generator
- Containers and tanks used by the generator to collect or consolidate wastes initially accumulated in other containers or tanks are subject to the same labeling requirements. The initial accumulation and “90-day period” dates on the “collection” container/tank must be the oldest of the initial accumulation and “90-day period” dates from the various containers/tanks emptied into the “collection” container/tank. This may require dates to be changed if wastes from “older” containers/tanks are added to the “collection” container/tank.
- In some cases, containers are continuously reused for accumulation of the same waste stream, such as when drums used to initially accumulate waste, which when full are emptied into larger “collection” containers. “Recurring use” labels may be used on such containers to revise the initial accumulation and “90-day period” dates (without having to change the other labeling information). If the container is emptied at least once each day, the word “daily” may be used in the date area of the label.
The U.S. Department of Transportation (DOT) requires hazardous waste generators to label and mark each package of hazardous waste before transporting the waste off site. The generator must placard the waste or offer placards to the initial transporter.
For shipments of hazardous material and wastes, the DOT requires each non-bulk package (maximum capacity no more than 119 gallons) to display, at a minimum:
- The proper shipping name and identification of the hazardous material
- The name and address of the shipper and/or the designated recipient
- The diamond hazard labels for the primary (and most subsidiary) hazard classes of the hazardous material
The DOT also requires that labels be properly placed on the container so that they are not missed by handlers. The labels must appear in their entirety and should not be placed near any other markings on the surface. To avoid being missed, never place labels near the bottom of a container.
If multiple labels are needed due to multiple hazards, the DOT recommends a 6-inch space between labels. Place the primary hazard label above and to the left of the subsidiary hazard label.
The Environmental Protection Agency (EPA) requires that the generator “mark each hazardous waste container with a capacity of 119 gallons or less with the following words and information”:
HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
Generator’s Name and Address _____________.
Generator’s EPA Identification Number __________________.
Manifest Tracking Number ___________________.
There are several industry standards as well you should be aware of when ensuring your hazardous waste is properly labeled. According to the EPA, the following are some of the best practices used for marking your containers:
- All personnel should use the same method to label containers. This may include handwritten or prepared labels, for example.
- All waste handlers should be properly trained. Training should include understanding what markings on the labels mean.
- Include information about contents. Besides the start date and the words “hazardous waste,” information should include whether the contents are toxic, reactive or compatible.
- Apply DOT labels to the container when waste is first placed in the container. The label will be in place for shipment and provides information about the waste to drum handlers.
- Remove any old labels. Before reusing containers, make sure all old markings or labels are washed off or blacked out.
Proper compliance with state and federal regulations is essential to maintaining a safe workplace for your employees and community.
While each entity has its own specific requirements for labeling hazardous waste containers, there is no requirement in regards to format or layout of the actual label. There are pre-printed labels commercially available, or you can download our free hazardous waste labels to use on your storage containers.