If you don’t follow protocol when it comes to how to label hazardous waste, you’re running several risks. That includes fines for improperly packaging your waste, but more importantly, you put anyone in contact with that waste in potential danger. Labels on hazardous material are meant to alert people in a clear, easy way about the dangers of that waste, and if the labels aren’t accurate—or are missing altogether—people have no way of getting that information.
Label Hazardous Waste Properly: Everything You Need to KnowThe Hazardous Waste Label Itself
Every drum filled with hazardous materials requires the yellow hazardous waste label.
That label includes important information, such as the following:
Does the Accumulation Start Date of Hazardous Waste Matter?
Yes! A large quantity generator has to ship all hazardous material every ninety days. Therefore, the label must include that important accumulation start date.
If you’re ever inspected or audited, this number must not only be present on the label but accurate. Failure to comply with this regulation can bring financial consequences or even stricter penalties, depending on the severity of the offense and if this is your first violation versus being a persistent problem.
Use of the Proper Placard on Hazardous Waste
The placard is going to contain crucial information, such as whether the contents of the drum are flammable, corrosive, oxidizers, etc.
For example, some hazardous materials can’t get wet. Ensuring the placard is properly created with a correct EPA waste code would tell firefighters to use foam rather than water if there were an accident involving that waste.
Without this proper placard, everyone would be put at needless risk if anything unexpected happened during transport of that waste. State of decay 2 close combat.
In this way, proper labeling is not about trying to dodge fines or avoid punitive actions. It’s truly about helping ensure the safety of anyone who comes in contact with that waste.
Ensure the Label and the Hazardous Waste Manifest Match
All the information on the labels you create should match the hazardous waste manifests. For one, this helps implement accuracy in regards to what information is placed on both the label and the manifest. But two, it potentially helps first responders in case of an accident. If firefighters or police officers can’t get safely to the drum, they can read the manifest and know how best to approach this particular accident. And the same if true vice versa. If they can’t reach the manifest, the pertinent information will be included on that yellow label on the drum itself.
Use Common Sense When It Comes to Hazardous Waste Labels
Always follow the letter of the law when it comes to these labels, but also make sure to execute good judgment. For example, the label needs to be in a clear and visible place on the drum. That way, if emergency response crews (or anyone, for that matter) needs to get the information contained on that label, it is as easy and convenient as possible.
There should also be a level of consistency regarding these labels. That is, everyone creating and dealing with these labels should be using the same system. This helps ensure less ambiguity about what the information on the label actually means.
Key Takeaways
For more information about how to properly and safely label your hazardous waste, please feel free to contact a representative of MCF Environmental Services, an established, reputable waste management Atlanta company.
While there are neither “official” nor “EPA-endorsed” hazardous waste labels, there are certain EPA and DOT requirements for marking chemical hazardous waste containers that warrant your careful attention.
Hazard Label Medical Waste ManagementEPA Requirements
A container used for chemical hazmat onsite storage must be marked with the words “Hazardous Waste.” It must also exhibit the starting date for its accumulation along with information about its contents (e.g., toxic, reactive, ignitable, or corrosive).
If you’re reusing a container, make sure to remove the old labels. And whether new or used, make sure to place a label on a container the very first moment that a chemical hazardous waste is placed inside it. Otherwise you’re out of compliance—and your intention to have done so at your very first convenience won’t matter to an EPA inspector.
To avoid visual confusion, all your personnel should be using the same labeling method (e.g. handwritten vs. printed forms). And each of them should have a clear understanding of what the markings signify—regardless of whether he or she directly handles your chemical hazardous waste.
Also bear in mind that labeling requirements differ depending on the amount of chemical hazardous waste you generate. In this regard, the EPA specifies two categories: Bulk-packaging and Non-bulk packaging.
Loosely speaking, non-bulk packaging dictates a maximum capacity of 119 gal. for a liquid waste (450 L); a maximum of 882 lbs. for a solid waste (400 kg); or a water capacity of 1000 lbs. for a gaseous waste (454 kg). Thereby, bulk-packaging is anything that exceeds these quantities.
DOT Requirements
There are also specific DOT requirements for shipping your chemical hazardous waste offsite for disposal, storage, or treatment.
Not only must the container be clearly labeled as hazmat, it must also prominently display this notice: HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
Additionally, the container must clearly show your company’s name, EPA identification number, and manifest tracking number; and there might be additional requirements for bulk-packaging containers (see above).
Labeling must be durable, clearly visible, and written in English. It must be displayed on a contrasting color background and not be obscured by other labels, attachments, or advertising.
“Labeling” vs. “Marking”
For DOT purposes, the word “labeling” is a very specific thing and is applicable only to bulk-packaging (see above). “Labels” are always diamond-shape; and their size must adhere to international standards, measuring at least 4″ x 4″ (100 mm) on each side, square-on-point. Everything else (applicable to non-bulk packaging) is merely “marking.”
The DOT uses nine categorical HazMat labels:
Summary
While neither the EPA nor DOT specify a format for labeling chemical hazardous waste containers, each requires specific information to be prominently displayed.
You’re free to use commercially-available printed labels that accommodate handwritten data—or any other means—so long as you’re consistent and include the required information.
Alternatively, you can buy PC software that allows you to enter the required information and then print formatted labels with your desktop printer.
If you need any help, call PegEx at (800) 936-2311. We have hazardous waste experts available to assist you.
Hazardous Property Requiring Special ProcessingRegulationsHAZMAT Disposal RegulationsDoDM 4160.21 Vol4 Required Documents
The following guidance outlines procedures for the turn-in of hazardous material (HM) hazardous waste (HW), and other types of waste. Some HW may require disposal on a hazardous waste disposal contract in compliance with federal/state/host nation regulations, when discarded for disposal. These procedures are intended to assist commanding officers, accountable supply officers, environmental staff and generating activities in the day-to-day conduct of business with the Disposition Services site. It is not possible to identify the universe of regulatory requirements in this guidance, however, basic turn-in requirements are addressed. To ensure compliance with federal, statute and/or DoD regulations, it is necessary that turn in activities obtain and become familiar with applicable Codes of Federal Regulation (CFRs), state regulations, DoD regulations, and overseas, by the OEBGD or the Final Governing Standards (FGS) for the host nation.
Summary of Preparatory Steps
Detailed turn-in requirements are outlined at ensuing paragraphs. Your servicing Disposition Services site is available to provide additional information and assistance in preparing hazardous property and documentation for turn-in.
Identification of Hazardous Property
Hazardous Property (HP) must be properly identified. Your responsibilities include identifying hazardous property as either hazardous material (HM) or as hazardous waste (HW) based on the definitions of HM and HW in DoDM 4160.21 and various federal/state/local/foreign country laws and regulations. The following guidance is based on DoD policy and shall be used in conjunction with applicable federal, state, and/or local environmental regulations
The list below is property requiring special processing, which is subject to unique regulatory constraints, because of the nature of the property or its container. Some types of property may be processed for R/T/D/S, and other property on the list, may have to be processed directly to disposal. See disposal guidance in DoDM 4160.21, Chapter 10, Attachment 1.
Turn-In Instructions for Hazardous Property
All property must be accompanied by a properly prepared DD Form 1348-1A, Disposal Turnin Document (DTID), according to DoD 4000.25-1-M, MILSTRIP. A minimum of an original and three legible copies must accompany property turned in for disposal processing. If a copy is needed for the delivery agent, an original and four legible copies must accompany the property.
Responsibilities for Receipt and DisposalOccupational Safety and Health Act (OSHA) Compliant Label
Material Safety Data Sheet
The MSDS is an OSHA requirement levied on chemical manufacturers to provide specific information about the chemicals they produce and sell. The MSDS must accompany the product(s) when sold. Subsequently the buyer, or whoever uses the chemicals, must maintain the MSDS in their plant or storage area, to ensure the MSDS information is available for the safety of the employees who use or handle the chemicals. The MSDS is prepared by private industry and must be prepared by professional chemists and/or industrial hygienists who know and understand the chemical and physical properties of the chemicals, and who sign and verify its correctness. OSHA (29 CFR) provides a specific outline of what must go in an MSDS. DLA or DoD employees (unless they are chemists or industrial hygienists who has responsibility to prepare MSDSs) do not prepare, verify or sign an MSDS.
Turn-in activities shall provide a hard copy MSDS, or indicate on the DTID the MSDS five digit alpha code from the Hazardous Material Information System (HMIS), with turn-ins of unused, unopened HM, and with used and/or opened HM. he MSDS must match the specific manufacturer of the hazardous material and should include the manufacturer's name or CAGE code In addition to an MSDS, used and/or opened HM requires that the chemical name of any hazardous contaminants and the noun name of any non-hazardous contaminants be identified on the DTID. Used and/or opened HM may have become contaminated with constituents not reflected on the MSDS. A Hazardous Waste Profile Sheet may also be required for used/opened HM going directly to waste disposal contract. Hazardous Waste Profile Sheet (HWPS)
Turn-in activities are required to provide a Hazardous Waste Profile Sheet, DRMS Form 1930 with the turn-in of each initial waste stream and once a year thereafter
A HWPS is required with turn-ins of HW and used and/or opened HM that meets the definition of a HW when discarded by disposal service contract. Used and/or unopened HM is considered contaminated and may not be the same property described in an MSDS
Generators will complete the form by providing requested information or by entering 'N/A' when applicable. The information may be based on user's knowledge and/or laboratory analysis of the waste. Supporting documentation may be required if user's knowledge does not identify or characterize the waste sufficiently or correctly
Supporting documentation consists of chemical analysis, description of waste production processes including raw materials, end products, and other sources of how the waste was generated
After the initial turn-in of the waste, turn-ins of identical waste will not require a HWPS; instead, generators will enter a Disposition Services site-assigned HWPS reference number in block 27 of the DTID
The turn-in activity shall certify each HWPS annually by either providing to the Disposition Services site a new signed and dated HWPS or an electronically transmitted HWPS for each waste which will be generated during the following year
For overseas, assign the host nation or IMDG shipping description
Laboratory chemicals are exempt from waste profile requirements provided they are processed according to DoDM 4160.21, Chapter 10, Attachment 1
Marking and Labeling
Hazardous property shall be marked and labeled in conformance with established environmental, safety and transportation laws and regulations
Turn in activities are required to ensure that HM is properly labeled according to 29 CFR requirements. OSHA compliant hazard warning labels, tags or markings are required to be completed and attached/affixed to all HM except for the specific exclusions found in DoDM 4160.21
Before transporting HM/HW off-site, generators must label and mark each package according to DoT/EPA regulations. Labeling and marking requirements for transport of HW are prescribed in 40 CFR 262.31 and 262.32. Marking and labeling requirements for both HM and HW are prescribed in 49 CFR 172, Subparts D and E.
PCB markings requirements are prescribed in 40 CFR 761. Items containing 50 ppm or more PCB must be marked, with the exception of transformers. Only transformers with 550 ppm or more PCB must be marked
Friable asbestos packages must be labeled with the following wording:
DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD
Placarding. Before transporting HM/HW off-site, generators must placard or offer the initial transporter the appropriate placards according to 49 CFR 172, Subpart F
Forms1348-1A
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