Labeling Hazardous Waste Containers for Off-Site Transportation

Part 1 of this series covered federal (RCRA) requirements for hazardous waste accumulation labels, and Part 2 covered California accumulation label requirements, but what about labeling requirements for off-site shipment for disposal? In order to transport a hazardous waste container for disposal, the container must meet U.S. Department of Transportation (DOT) requirements for hazardous materials shipments in addition to applicable state/federal hazardous waste labeling requirements, since hazardous waste is, by definition, a hazardous material. RCRA regulations (40 CFR § 262.32) require the following information on containers prepared for off-site transportation:

• The words “Hazardous Waste”
• The statement “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, address and EPA identification number
• Manifest Tracking Number
• EPA Hazardous Waste Codes

DOT regulations (49 CFR § 172.301) also require the following information for non-bulk containers (< 119 gallons):

• The complete DOT shipping description including UN identification number, “Proper Shipping Name” (PSN), Hazard Class/Division (including subsidiary hazards), Packing Group and “Reportable Quantity” (RQ), if applicable
• The name and address of the designated recipient
• DOT hazard label(s) for the material

There are specific size requirements for the UN/NA numbers:

• The UN/NA number on packages with a maximum capacity of 5 L (1.3 gal.) or 5 kg (11 lbs.) or less “must be marked in a size appropriate for the size for the package”
• Packages with a maximum capacity of 30 L (8 gal.) or less, or 40 kg (66 lbs.) max. gross weight, or cylinders with a capacity of 60 L (16 gal.) or less must be marked with characters at least 6 mm (0.24 in.) high
• Larger packages must be marked in characters at least 12 mm (0.47 in.) high

That’s it for hazardous waste shipping labels. We already covered federal and state accumulation container labels in Parts 1 and 2 of this 3-part series. Remember, though, that this is just a brief summary of DOT hazardous materials shipping issues – there are some other DOT issues for bulk shipments (> 119 gallons), some specific requirements for different hazard classes and a variety of exemptions and exceptions. 49 CFR Part 172 has complete information on DOT labeling requirements, but if you have any other questions about off-site shipping, transportation 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