Hazardous Waste Container Labeling Requirements

Hazardous waste labels and overpacking.
Hazardous waste container labeling requirements. Pre transport requirements package and label hazardous waste for shipment off site to a rcra facility for treatment storage or disposal. New label requirements are in effect as of april 28 2019. Good faith effort required 262 27. Epa developed this presentation to explain the container labeling under the academic laboratories rule subpart k of part 262 in title 40 of the code of federal regulations cfr.
Labeling and marking of all hazardous waste containers appropriately according to both epa and dot requirements is necessary in properly dealing with the waste cradle to grave. The epa primarily determines the types or classes of hazardous waste to be marked and how waste containers should be labeled to communicate this. 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. Generators that accumulate hazardous waste in containment buildings are subject to article 29 of chapter 15 and must meet additional documentation and record keeping requirements.
While there are neither official nor epa endorsed hazardous waste labels there are certain epa and dot requirements for marking chemical hazardous waste containers that warrant your careful attention. All containers and tanks i e for lqgs and sqgs must be labeled hazardous waste marked with the date accumulation begins. A container used for chemical hazmat onsite storage must be marked with the words hazardous waste. Whenever hazardous material packages are overpacked the inner containers must be properly labeled in accordance with dot shipping requirements for the hazardous material.
Program in place required 262 27. The dot recommends a six inch space 150mm between labels. The same applies to the overpack container. Epa labeling requirements at the federal level rcra rules for container labeling as well as labeling of tanks and containment buildings were recently revised as part of the generator improvement rule gir process.
Training material on hazardous waste container labeling requirements under the academic laboratories rule. The biggest changes are to the requirements for labeling hazardous waste. The regulations reference the dot hmr in 49 cfr part 172 for hazardous waste labeling marking and placarding requirements. The updated regulations are found in title 40 of the code of federal regulations part 262 40 cfr 262.
The washington state department of ecology has updated the hazardous waste regulations to incorporate the epa s new generator improvement rules. Under the new rules if you generate hazardous waste in containers larger than four liters the words.