Grabbing an adhesive label from the local Office Depot store and writing the words “Hazardous Waste” on it, then slapping it on a storage container and placing it in the warehouse is if nothing else going to give your local DTSC inspector a a good laugh. But it won't get you out of a fine, and even worse it may create a dangerous environment for your employees.
It cannot be stressed enough how important it is for your business to properly label hazardous waste containers.
Hazardous waste generators that accumulate hazardous waste on-site in containers must be aware of the Resource Conservation and Recovery Act (RCRA) regulations regarding the proper labeling, marking and placarding requirements for hazardous waste containers.
If you are a hazardous waste generator, once you’ve placed any hazardous waste into a container it becomes necessary to properly mark and label that container.
The California Department of Toxic Substances Control (DTSC) provides the following guidance for the proper labeling requirements for California hazardous waste generators pursuant to Title 22, California Code of Regulations (Cal. Code Regs.):
Before transporting hazardous waste off-site, or offering hazardous waste for off-site transport, a hazardous waste generator must label (40 CFR 262.31) and mark (40 CFR 262.32) each package of hazardous waste, and must placard the waste or offer placards to the initial transporter (40 CFR 262.33). The regulations reference the DOT HMR in 49 CFR Part 172 for hazardous waste labeling, marking, and placarding requirements.
In order to comply with Department of Transportation (DOT) regulations, proper DOT labels must be filled out before the container can be shipped off site. This label is used to identify each waste stream including its name, characteristics, and handling requirements.
Having proper labels on the container is not the only concern. It is also important to place the labels properly on the container. This is important so that labels are not missed by handlers. Labels must appear in their entirety and should not be placed near any other markings on the surface. They should always be visible, so never place them on the bottom of a container.
If the waste has multiple hazards associated with it multiple labels should be displayed next to each other. The DOT recommends a six- inch space (15 cm) between labels. The label designating the primary hazard should be above and to the left of the label designating the subsidiary hazard.
The EPA provides the following best practices that are used as industry standards for properly labeling/marking your containers:
Follow these tips and you can ensure proper compliance with RCRA and DOT regulations and maintain a safe workplace for your employees, company and community.
Get our free hazardous waste labels to use on your storage containers.