In an earlier article I explained all of the new marking and labeling requirements for all stages of hazardous waste management (central accumulation area, satellite accumulation area, preparation for off-site transportation, 10-day transfer site, and treatment, storage, and disposal facility or TSDF) for all hazardous waste accumulation units (container, tank ,drip pad, & containment building) at all hazardous waste handlers (generator, transporter, or TSDF) of the Generator Improvements Rule.  Read it here if you’re interested: Marking and Labeling of Hazardous Waste Accumulation Units Under the Generator Improvements Rule.

For this article I decided to focus on just one very important requirement: the labeling and marking of a hazardous waste container by the generator to prepare for off-site transportation and its revision under the Generator Improvements Rule.

Before we begin…

• These regulations apply solely to a large quantity generator (LQG) and small quantity generator (SQG) of hazardous waste.  They do not apply to the (recently renamed) very small quantity generator (VSQG).

Very little has changed under the Generator Improvements Rule for the marking of a container of hazardous waste at an SQG or LQG prepared for off-site transportation.  The regulations are found at 40 CFR 262.32(b-d).  Prior to the Generator Improvements Rule it required solely the following:

• “Hazardous Waste”
• “Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”
• Generator’s Name and Address ____.
• Generator’s EPA Identification Number ____.
• Manifest Tracking Number ____.

As of the effective date of the Generator Improvements Rule a container of hazardous waste prepared for off-site transportation must now include the following in addition to the above:

• EPA Hazardous Waste Number(s) ____.

Note:

• Lab packs that will be incinerated in compliance with §268.42(c) are not required to be marked with EPA Hazardous Waste Number(s), except D004, D005, D006, D007, D008, D010, and D011, where applicable.
• A generator may use a nationally recognized electronic system, such as bar coding, to identify the EPA Hazardous Waste Number(s).
• This requirement applies solely to containers with a capacity of 119 gallons or less (i.e. what USDOT refers to as a non-bulk packaging).