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Is Your Hazardous Waste Labeled Correctly?

Kevin Webber - Nov 20, 2018 7:45:00 AM

Hazardous-Waste-LabelsProperly labeling your hazardous waste materials is one of the most important activities for a compliant waste management regime. From notifying personnel of the dangers involved in dealing with a material, to ensuring your waste management provider is able to handle each material appropriately, labels are crucial for maintaining safe operations.

Even minor hazardous waste labeling violations can lead to steep penalties and fines. The EPA is authorized to levy financial penalties of more than $72,000 per violation, per day for any failure to comply with the Resource Conservation and Recovery Act (RCRA), including “simple” labeling mistakes.

In 2018, operators of the Grand Coulee Dam in Washington State were assessed a $115,000 penalty by the EPA for violations including mislabeled hazardous waste products. Additionally, in 2017 a hospital in South Carolina was fined $28,000 by the EPA due to a mistake that lead to non-hazardous waste being labeled as hazardous—serving as a reminder that mistakes of any kind can lead to penalties when it comes to strict regulatory adherence for waste management, even when there was never a genuine risk of hazardous waste exposure or release.

Given the steep consequences for compliance failure, how do you ensure your facility meets all legal requirements for labeling your hazardous waste?

A fully certified and knowledgeable waste management provider is a great source to consult with questions about your facility’s individual operations, but you also need to understand the requirements yourself in order to properly train employees and administrate your facility’s waste management regime.

Here’s what you need to know.

What Your Hazardous Waste Labels Must Include

The primary purpose of hazardous waste labels is to notify observers about what material is contained in waste containers, along with alerting them to the attendant regulatory requirements for handling and managing that waste.

In order to prepare your facility’s hazardous waste products for transport in any capacity, you’re required to mark or affix labels to each individual waste container that comply with the standards laid out in 49 CFR Part 172.

Specifically, before you transport hazardous waste off-site, each container capable of holding 119 or fewer gallons must be labeled with the following information as outlined in 49 CFR 172.304:

  • Written verbatim: “HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”
  • Your company’s operating name and the facility’s address
  • Your facility’s EPA Identification Number
  • A unique manifest tracking number
  • All relevant EPA hazardous waste numbers—note that you’re allowed to use methods like barcodes to convey the waste number, as long as those methods are commonly interoperable and recognized nationally

You’re also required to record the accumulation time for the waste material in each individual container.

Small quantity generators must include a label that is easily visible for inspection and clearly marks the start date of waste accumulation in the container. While the container is stored on-site, it must be clearly labeled with the words “Hazardous Waste."

Large quantity generators must follow the same regulations, but are additionally required to affix compliant labels or markings on all large storage tanks, as well as any smaller portable containers.

The same labeling requirements apply to containers used to consolidate or collect hazardous waste throughout your facility, even if those containers will always remain on-site. In that case, containers that are used to accumulate a single waste stream—and are then emptied into larger consolidation containers—may include “Recurring Use” labels that you must update as necessary to accurately track the accumulation times and total storage time limits.

Specific Requirements for Hazard Class or Division

All hazardous waste labeling must include classification codes related to the hazard class or division as defined by the RCRA and subsequent regulations.

You can use this table to identify hazardous materials and determine what label codes are required according to the relevant reference section:

Hazard class or division

Label name

Label design or section reference

1.1

EXPLOSIVES 1.1

172.411

1.2

EXPLOSIVES 1.2

172.411

1.3

EXPLOSIVES 1.3

172.411

1.4

EXPLOSIVES 1.4

172.411

1.5

EXPLOSIVES 1.5

172.411

1.6

EXPLOSIVES 1.6

172.411

2.1

FLAMMABLE GAS

172.417

2.2

NONFLAMMABLE GAS

172.415

2.3

POISON GAS

172.416

3 Flammable Liquid (Combustible liquid)

FLAMMABLE LIQUID (none)

172.419

4.1

FLAMMABLE SOLID

172.420

4.2

SPONTANEOUSLY COMBUSTIBLE

172.422

4.3

DANGEROUS WHEN WET

172.423

5.1

OXIDIZER

172.426

5.2

ORGANIC PEROXIDE

172.427

6.1

POISON INHALATION HAZARD

172.429

6.1

POISON

172.430

6.1

POISON INHALATION HAZARD

172.429

6.1

POISON

172.430

6.2

INFECTIOUS SUBSTANCE1

172.432

7

RADIOACTIVE WHITE-I

172.436

7

RADIOACTIVE YELLOW-II

172.438

7

RADIOACTIVE YELLOW-III

172.440

7

FISSILE

172.441

7

EMPTY

172.450

8

CORROSIVE

172.442

9

CLASS 9

172.446

Once you’ve worked with your waste management provider to determine the hazardous material classification, all containers must be labeled according to column 6 in the Hazardous Materials Table provided by the federal government.

After determining how your facility’s hazardous waste material should be labeled for proper storage and transport, it’s crucial to train all employees and managers to strictly uphold those requirements. Even the smallest lapses in adherence could lead to steep penalties and fines, along with endangering employees and the surrounding environment.

Through regular consultation with your waste management provider and clearly understood labeling practices, you can ensure your facility remains safe and compliant, both now and in the future.

Topics: Hazardous Waste

Kevin Webber

Kevin Webber

Articles written by Kevin Webber who is one of the partners at TriHaz Solutions.

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