Generators of hazardous waste should be aware of the packaging requirements of the U.S. Department of Transportation (USDOT) when shipping their hazardous waste off-site for final treatment and disposal:  the packaging must be in good condition, approved by the USDOT for the use of hazardous materials, it must be labeled per DOT requirements, and it must be closed and sealed to prevent a release during transportation.

What aren’t as clear are the U.S. Environmental Protection Agency (USEPA) requirements for a “closed container” while the waste is accumulated on-site.  In order to answer this question – which has come up many times during my training events – I relied heavily on a USEPA memorandum: Guidance on 40 CFR 264.173(a) and 265.173(a):  Closed Containers. (more…)