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