Tech Corner: Know your hazardous waste accumulation & storage rules

One notable change triggered by the Hazardous Waste Generator Improvement rule is the marking and label requirements on hazardous waste accumulation containers while in satellite waste accumulation and in central waste storage.  Previous RCRA labeling regulations did not require generators to identify and indicate the specific hazards of the hazardous waste accumulated in containers, tanks, drip pads and containment buildings.  This resulted in a failure to communicate risks associated with wastes being accumulated or stored in different locations.

Another risk associated with marking and labels was the Treatment Storage Disposal Facility (TSDF) not knowing how to treat the waste to meet land disposal restriction requirements because generators did not always identify the specific RCRA waste codes associated with the waste.

To avoid these risks the following changes to hazardous waste management regulations have been applied:

1.       Satellite accumulation – Containers and tank labels must have the words “Hazardous Waste” and the hazards of the contents.  For containment buildings, the generator must have a sign in a conspicuous place with the words ”Hazardous Waste” and the hazards of the waste. See example below. (40CFR§262.15)

2.       Central waste storage – Containers and tank labels must have the words “Hazardous Waste” and the hazards of the contents.  Also before transporting for disposal, generators must mark their containers with the applicable RCRA waste codes or use a bar-coding system that performs the same function. See example below. (40CFR§262.32)

For additional information on marking and labeling associated with accumulation and storage areas contact your local enviroexpert.