Effective May 30, 2017, the EPA put into effect the Hazardous Waste Generator Improvement Rule, requiring authorized states to adopt changes in situations where the new rule is more stringent than existing state rules. But which changes will impact your organization, and what do you need to do about them? Let’s break it down.
One change affecting small quantity generators (SQG) and large quantity generators (LQG) concerns marking, labeling, and noting hazardous waste numbers to improve communication with workers and emergency responders. To look up your appropriate hazardous waste number and code, and prevent noncompliance or mischaracterization of waste, view the EPA definitions list. This new rule applies to SQGs and LQGs, but not to very small quantity generators (VSQG), which were formerly known as conditionally exempt quantity generators (CEQG). To determine which category your volume of hazardous waste generated falls into, view the EPA categories. The new rule also applies in both satellite accumulation areas (SAAs), central accumulation areas (CAAs), tanks, and transportation storage and disposal facilities (TSDFs).
Under the new rule, hazardous waste container labels must include the contents at the point of generation. Prior to this new rule, you could create a label with either the words “Hazardous Waste” or a description of the contents. Now, the markings on a container are required to have both. The purpose of this change is to enhance communication and reduce confusion, which helps on-site workers handling the container and emergency responders to speak the same language.
(NOTE: The labeling requirements in the May 30th improvements are more stringent than previous federal rulings, and, after July 1, 2018, will be equal to or stronger than most existing state regulations. Some states may have already instituted these stronger labeling requirements, so confirm the circumstances in your location before you proceed.)
Containers containing hazardous waste must be marked at the point of generation with not only the words “Hazardous Waste” but also:
Other words that describe the content (i.e. chemical name or class of chemical such as organic solvents or DOT shipping name)
An indication of the hazard (e.g. ignitable, corrosive, reactive, toxic) or a hazard class label consistent with DOT requirements
It is important to note there have been no changes to requirements regarding when to apply a date to containers.
There are several EPA-labeling options approved by the EPA that your organize can use:
- Department of Transportation (DOT) 49 CFR part 172 subpart E: identifies 9 classes of hazardous materials. Each class has a number, color, and symbol on a diamond shaped label. Some classes have subdivisions and additional symbols.
Occupational Safety and Health Administration (OSHA) hazard communication standard 29 CFR 1910.120: focuses on classes of health risks and the degree of the hazard rather than the hazardous characteristic of the material.
National Fire Prevention Administration (NFPA) code 704: number ranking and diamond color labeling system that informs workers on the health hazard, fire hazard, reactivity level, and the specific hazard at hand (i.e. alkaline, acidic, corrosive, radioactive)
United Nations Global Harmonized System (GHS): classifies chemicals based on physical hazards, health hazards, and environmental hazards.
Antea Group recommends DOT labels because they are already required before transporting (why label twice?) and they cover the last two action criteria in the new improvement rule. However, selecting a labeling system is highly dependent on what works best considering your existing client hazard communication systems, local emergency responders, and worker training programs. Check back here soon for further explanation and insights on the new rule and what it means for you.
If you need clarification on labeling or help understanding these new changes, contact us today.
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