Logo

RCRA Hazardous Waste Labeling Requirements

Category:
Author: Marketing
Date: February 3, 2024

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

ALL BRANCH LOCATIONS

*ACTenviro has National service and consulting capabilities across the US

California
San Jose (Corporate Offices and Working
Facility)
967 Mabury Road
San Jose, CA 95133
Phone: (408) 548-5050
24.7 ER: (866) 348-2800
Fax: (408) 548-5052
Dixon
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
SUNNYVALE
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
sacramento
4 Wayne Court, Building 9
Sacramento, CA 95829
Phone: (916) 299-4228
inland empire
600 Iowa Street
Redlands, CA 92373
Phone: (909) 406-4400
merced
265 Riggs Avenue
Merced, CA 95341
Phone: (209) 722-4228
Fax: (209) 722-8228
Oregon
portland
13600 SE Ambler Road
Clackamas, OR 97015
Phone: (971) 279-6780
New Mexico
ALBUQUERQUE
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
ARIZONA
Phoenix
6212 S 75th Avenue #4
Laveen Village, AZ 85339
Phone: (602) 842-9160
Tucson
5568 N Camino De La Tierra
Tucson, AZ 85705
Phone: (520) 471-4672
Texas
dallas
4730 Bronze Way
Dallas, Texas 75236
Phone: (469) 518-6400
Fax: (469) 518-6402
HOUSTON
1700 North E Street
La Porte, TX 77571
Phone: (713) 568-2500
Fax: (713) 568-2501
Colorado
denver
4295 Kearney Street
Denver, CO 80216
Phone: (720) 386-2900
Pennsylvania
Fort Washington
500 Office Center Drive
Suite 400
Fort Washington, PA 19034
Phone: (626) 224-1666
Washington
spokane
1809 E. Houston Ave
Spokane, WA 99217
Phone: (509) 503-1300
Fax: (509) 503-1301
seattle
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
crossmenu