California Hazardous Waste Labeling Requirements

Author: Marketing
Date: August 14, 2015

As we learned in Part 1 of this 3-part series, 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 and updated regulations can be found in title 40 of the Code of Federal Regulations, Part 262 (40 CFR § 262).

Under RCRA, individual states are also allowed to establish their own regulations that are more stringent than RCRA requirements, including waste container labeling requirements. Some state-specific variations to RCRA container labeling requirements are relatively minor. For example, the State of Washington requires that wording on waste container labels be “clearly visible” from 25 feet away or have lettering size at least ½” in height. In California, the differences in labeling requirements are a little more significant, mainly due to other differences in California hazardous waste regulations.

Similar to the RCRA requirements, California regulations (22 CCR § 66262.34(f)) require the following on each waste container:

  • The words “Hazardous Waste”
  • The accumulation start date (the date the first waste was placed in the container)
  • The hazardous properties of the waste (i.e., flammable, corrosive, reactive, toxic)
  • Composition and physical state of the waste
  • Name and address of the person producing the waste

The accumulation start date for California generators (SQGs and LQGs – see Part 1 for definitions) is the date that waste was first placed in the container. This date must be indicated on all hazardous waste container labels, even SAA labels, because California regulations (22 CCR § 66262(e)) limit accumulation time to a maximum of year, even if the waste is kept in an SAA.

  • As an alternative, some local California regulators allow generators to indicate “Emptied Weekly” or “Emptied Daily” for accumulation start date on SAA containers that are consolidated into larger containers, as long as the consolidation containers are labeled appropriately.

In addition to the accumulation start date, waste containers should also be marked with the date they exceeded SAA quantity limits and/or were moved to CAA to demonstrate compliance with the CAA time limit of 90 or 180 days, depending on generator status.

That’s it for California hazardous waste accumulation area labeling. Part 1 of this 3-part series addressed RCRA requirements for waste accumulation and Part 3 will conclude the series with a discussion of labeling requirements when shipping your waste off site for disposal.

If you have any questions about California regulations, container labeling or any other hazardous waste issues, ACTenviro is available to help! Contact us at [email protected].

– James Kapin, MPH, CIH, CSP
Director of EM Services


*ACTenviro has National service and consulting capabilities across the US

San Jose (Corporate Offices and Working
967 Mabury Road
San Jose, CA 95133
Phone: (408) 548-5050
24.7 ER: (866) 348-2800
Fax: (408) 548-5052
6940 Tremont Road
Dixon, CA 95620
Phone: (800) 559-3274
Los angeles
12235 Los Nietos Road
Santa Fe Springs, CA 90670
Phone: (714) 545-2191
1210 Elko Drive
Sunnyvale, CA 94089
Phone: (408) 548-5050
Fax: (408) 548-5052
san diego
2010 W Mission Road
Escondido, CA 92029
Phone: (858) 925-2500
4 Wayne Court, Building 9
Sacramento, CA 95829
Phone: (916) 299-4228
inland empire
600 Iowa Street
Redlands, CA 92373
Phone: (909) 406-4400
265 Riggs Avenue
Merced, CA 95341
Phone: (209) 722-4228
Fax: (209) 722-8228
13600 SE Ambler Road
Clackamas, OR 97015
Phone: (971) 279-6780
New Mexico
208 Murray Road SE
Albuquerque, NM 87105
Phone: (505) 445-9400
Fax: (505) 445-9401
ACTreatment (TSDF)
6137 Edith Boulevard NE
Albuquerque, NM 87107
Phone: (505) 349-5220
Fax: (505) 344-7986
El Paso
511 Highway 213
Chaparral, NM 88081
Phone: (575) 824-0164
6212 S 75th Avenue #4
Laveen Village, AZ 85339
Phone: (602) 842-9160
5568 N Camino De La Tierra
Tucson, AZ 85705
Phone: (520) 471-4672
4730 Bronze Way
Dallas, Texas 75236
Phone: (469) 518-6400
Fax: (469) 518-6402
1700 North E Street
La Porte, TX 77571
Phone: (713) 568-2500
Fax: (713) 568-2501
4295 Kearney Street
Denver, CO 80216
Phone: (720) 386-2900
Fort Washington
500 Office Center Drive
Suite 400
Fort Washington, PA 19034
Phone: (626) 224-1666
1809 E. Houston Ave
Spokane, WA 99217
Phone: (509) 503-1300
Fax: (509) 503-1301
2923 S J Street
Tacoma, WA 98409
Phone: (253) 357-5200
Fax: (253) 357-5201
Copyright © 2024 ACTenviro. All Rights Reserved
Anthem MRF | Resources | Glossary | Terms & Conditions | Privacy Policy
footer logo