Common Hazardous Waste Management Mistakes (Part 2): Hazardous Waste Labeling

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When it comes to continuous improvement, the primary focus of the majority of industrial facilities is production. This type of industrial management is a sensible approach, as production can have the greatest impact on the facility’s profitability. However, singularly focusing on products generated by a facility while ignoring waste generation can be costly not only from a financial perspective but also from a regulatory compliance perspective as well.

In order to decrease the possible risks associated with improper waste management, it is beneficial to examine some of the more common mistakes made throughout industry. This ensures that a facility has a solid foundation from which to build out a waste management program that covers the proper handling of all of its waste streams.

Mistake #4: Missing or Incomplete Container Labeling

Containers storing waste must be properly labeled in order to ensure that the waste and its associated hazards are properly identified. A Hazardous Waste Label must have the following detailed information:

  • The words: “Hazardous Waste”
  • Generator Information
    • Name
    • Address
    • Phone Number
    • EPA Identification Number
  • EPA Waste Code
  • Waste Description
  • Accumulation Start Date

The Generator Information must be included to ensure that the waste can be attributed to the correct facility. It is important to note that a facility retains responsibility for its hazardous waste from generation, through the transportation process, and all the way until the waste reaches the disposal facility for final management. The EPA Waste Code is a four-digit shorthand reference that identifies the type and characteristics of hazardous waste. One of the most common codes is D001 which corresponds with Ignitable Waste. EPA Waste Codes serve as warnings through the identification of hazards associated with a particular waste. The Waste Description provides additional information which better describes the waste being stored. One example of this would be “Aerosol Can Waste” or “Spent Solvent”. This provides additional information to allow for employees handling the waste to take the proper precautions. The Accumulation Start Date is important as it dictates when a container of hazardous waste must be shipped off-site. The Accumulation Start Date must be marked either as soon as the waste is placed into the container or when a Satellite Accumulation container is filled and moved to the Central Accumulation Area.

Mistake #5: Misunderstanding the Start Accumulation Date

The Start Accumulation Date can vary depending on the type of storage utilized by a facility. Satellite Accumulation is one type of storage that takes place at or near the point of generation where wastes initially accumulate and is under control of the operator of the process generating the waste. Up to 55 gallons of hazardous waste (or 1 quart of Acute Hazardous Waste) can be stored at the Satellite Accumulation Area. Once the 55-gallon limit is reached, the container must be labeled with the Start Accumulation Date and moved to the Central Accumulation Area within 3 consecutive days.

For storage types other than Satellite Accumulation such as storage in tanks or containers larger than 55 gallons that will not be moved to a Central Accumulation Area, the Start Accumulation Date would be the day that hazardous waste was first placed into the tank or container.

As soon as the container is labeled with the Start Accumulation Date, the 90-day or 180-day time limit for accumulation starts. It is important to realize that, if possible, a facility should always take advantage of the less restrictive time requirements associated with Satellite Accumulation Containers. This can be very helpful for facilities that have Satellite Accumulation Containers that take long periods of time to reach the 55-gallon limit, such as waste from small Solvent Distillation Units or Aerosol Can Puncture Units. These types of hazardous wastes typically do not require disposal every 90 or 180 days. The time limit only starts after reaching the 55-gallon Satellite limit.

Mistake #6: Not Labeling Satellite Accumulation Containers

Non-Satellite Accumulation Containers such as tanks are required to be labeled and marked with a Start Accumulation Date as soon as any amount of hazardous waste is placed into the container. Satellite Accumulation Containers are not required to be marked with a Start Accumulation Date until the container reaches the 55-gallon limit and is moved to the Central Accumulation Area. This does not mean that the Satellite Accumulation Container is absolved of all other labeling requirements. The Satellite Accumulation Container must be labeled with all other pertinent information: “Hazardous Waste”, Generator Information, EPA Waste Code, and Waste Description as soon as any amount of hazardous waste is placed into the container.

What to do next?

If you find that your facility may need to consider addressing Waste Management issues onsite, Conversion Technology, Inc. (CTI) can provide consulting assistance to ensure that all of your issues and questions are addressed. CTI has had over 30 years of experience working with industrial facilities to assist in proper management of waste. This includes onsite Waste Management Audits, preparation of Hazardous Waste Reports, preparation of Hazardous Waste Contingency and Waste Minimization Plans, preparation of Hazardous Waste Fees, preparation of Site Identification Forms, and provision of Hazardous Waste Training. We will be happy to assist you with whatever consulting services you are in need of.

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