Hazardous waste marking requirements

Waste Handling and Disposal Methods for sink disposal rules, elementary neutralization, "Hazardous Waste" marking requirements, proper chemical name identification, closed container requirements, waste pick-up requests, bulking requirements, and satellite accumulation regulations. 

It is important to keep the amount of potentially hazardous waste in the laboratory to a minimum at all times. Periodically, contents of the laboratory waste containers will be transferred to appropriate containers for final disposal. These must be stored in a safe location, often outdoors, while awaiting pick-up by a disposal service. There will be local restrictions for such storage. A locked storage area may be needed, for example, to prevent unauthorized access to hazardous materials. The fire department niiay set strict limits as to how much flammable material may be present. All containers must be marked with contents, and the storage area will no doubt require warning signs. 

Hazardous waste must be packaged in accordance with DHS and Department of Transportation (DOT) requirements prior to shipment to a treatment, storage and/or disposal facility. Marking and labeling must also be in accordance with DOT guidelines. A hazardous waste label must be affixed to all hazardous waste containers. 

Section 171.2 forbids the offer or acceptance of a hazardous material for transportation within the United States unless it is packaged, marked, and labeled in accordance with DOTs regulations. Special requirements for import and export hazardous waste shipments, including the clear and legible display of required specification markings on the package, are set forth in 171.12. 

Under special EPA requirements, hazardous waste shippers must mark each shipping container of 110 gallons or less with this warning HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection... 

Additional Marking Requirements for Certain Hazardous Materials The regulations also require certain additional markings for packages containing radioactive materials, Other Regulated Materials (ORM), and hazardous substances and wastes. 

The nentralents generated by the EDS will primarily include hazardous waste and hazardous materials, which make them subject to RCRA and DOT requirements. If these are the only constituents, the neutralent could be transported as a rontine hazardous waste or hazardous material under existing laws and regulations as long as it is packaged, marked, manifested, and shipped as required by those regulations. 

The containers, normally drums, offered to the transporter or used by the commercial disposal firm must be marked with an appropriate label as defined in the tables in Parts 172.101 and 172.203. No container can be marked with a label for a material not in the container. Besides these DOT labels, EPA/RCRA regulations require each container to have a label stating prominently that the container contains a hazardous waste. The EPA/RCRA label contains much of the same information found on the shipping papers or manifests generator name and address, accumulation start date, manifest number, proper shipping name, and UN or NA number. Additional information may be provided by the gai ator. An example of a hazardous waste label is shown in Figure 4.13. If the container contains a hazardous chemical related by OSHA in a substance-specific health standard, a label identifying the material and the hazard must be on the container. Labels are to be placed within 6 inches of each other and must be on the side of the container, not the top. 

The EPA defines hazardous wastes in the RCRA. This waste also includes pharmaceutical wastes that contain toxic chemicals or exhibit properties that make them hazardous to the environment and/or humans. RCRA wastes include broken or spilled vials, partial vials, expired products, and patient s personal medications. EPA limits hazardous waste maximum storage time to 90 or 180 days based on generator status. All wastes must be stored in a separate and locked area clearly marked so that it cannot become a food source or breeding place for insects or animals. Like infectious wastes, there is no time limit to fill the container. Not all states mandate the same storage requirements. Contact local and state authorities for additional information. EPA s P-listed chemicals (40 CFR 261.33) include such pharmaceuticals as epinephrine, nicotine, chloroform, and warfarin over 0.3%. The U-listed chemicals (40 CFR 261.33) include many used in chemotherapy, such as paraldehyde, mercury, phenol, and warfarin under 0.3%. 

Proper Management — The waste is properly accumulated in containers, tanks, drip pads, or containment buildings. Hazardous waste containers must be kept closed and marked with the date on which accumulation began. Tanks and containers are required to be marked with the words Hazardous Waste. The generator must ensure and document that waste is shipped off site within the allowable 90-day period. 

Finally, packaging that contains the residue and/or vapor of a hazardous material must be marked as required when it previously contained a greater quantity of the hazardous material. The word waste need not be included in the proper shipping name, however, if the package bears the EPA marking prescribed by 40 C.F.R. 262.32. ... 

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