RCRA Hazardous Waste Labeling Requirements

As a hazardous waste generator, you know your waste containers need to be labeled, but sometimes it is not clear exactly what needs to be included on those labels. Requirements can vary depending on your state, where in your facility the waste is kept (Satellite Accumulation Area or Central Accumulation Area) and what you are doing with the waste (“accumulating” or “transporting”). We will review waste labeling requirements below, but first let’s clear up some terminology. When waste is being collected in “satellite accumulation areas” (SAAs) or “central accumulation areas” (CAAs) at a generator site, it is being “accumulated”, not “stored” (assuming the accumulation is consistent with state or federal SAA/CAA regulations). “Storage” is when waste is kept on site in excess of applicable SAA/CAA time limits and requires a permit (like at a TSD facility). So what we are talking about in the generator world are hazardous waste “accumulation” labels, not hazardous waste “storage” labels. 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. The updated regulations are found in title 40 of the Code of Federal Regulations, Part 262 (40 CFR § 262). Specific GIR provisions are still being adopted by individual states, and some states may have additional requirements, but under RCRA, hazardous waste in containers in CAAs must be labeled with the following:

• The words “Hazardous Waste”
• The date accumulation began (the date the waste exceeded SAA quantity limits or was moved into a CAA)
• An indication of the hazards of the waste

As long as containers are compatible with the materials they contain, containers holding incompatible materials are segregated, leaks and spills are addressed promptly and other large or small quantity generator responsibilities are met, then waste containers in SAAs only need to be labeled with the words “Hazardous Waste” and an indication of the hazards, since RCRA regulations do not establish time limits for waste in SAAs. See 40 CFR § 262.15 for more information. The GIR updates (if adopted by states) allow generators to maintain a “lower” generator status for a single planned or unplanned waste generation event that would otherwise push them into a higher generator status. Waste generated from these “episodic” events should be labeled with the words “Episodic Hazardous Waste” as well as an indication of hazards and the date the episodic event began. These requirements apply whether you are a whether you are a large-quantity generator (LQG) or Small Quantity Generator (SQG). See 40 CFR §262.16 or 40 CFR §262.17 for more information on requirements for SQGs and LQGs. What does “indication of the hazards” mean? RCRA regulations allow generators to use any of the following methods to indicate the hazards of the waste in the containers:

• Words indicating the applicable U.S. EPA hazardous waste characteristic(s): ignitable, corrosive, reactive or toxic
• DOT hazard communication pictograms indicating applicable DOT hazard class/division
• A hazard statement or pictogram consistent with the OSHA Hazard Communication Standard (29 CFR § 1910.1200)
• A chemical hazard label consistent with the National Fire Protection Association Standard 704 (NFPA 704 – Standard System for the Identification of the Hazards of Materials for Emergency Response)

Examples of acceptable hazard indicators for a flammable liquid waste can be seen in the image accompanying this piece. That’s it for federal hazardous waste accumulation labels, but things are different in California, and there are other requirements when shipping waste off-site. Part 2 of our series will review hazardous waste accumulation labeling requirements for California generators and Part 3 will conclude the series with a discussion of hazardous waste shipping labels for off-site transport and disposal. If you have any questions about DOT shipping, 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