Hazardous Waste Labeling and Marking
A critical step in the safe handling of a hazardous waste is labeling and marking all containers accordingly. To ensure uniformity in the labeling and marking of containers while the waste is being accumulated to its ultimate disposal, both the US Department of Transportation (DOT) and US Environmental Protection Agency (EPA) offer specific regulatory guidance for hazardous waste generators to follow. It is important to note that these requirements are different from the OSHA hazardous communication standard (29 CFR 1910.1200), which offers labeling guidance for hazardous waste materials that have not been designated as waste.
Because the DOT hazardous waste labeling and marking requirements are different based on the size of the container, it is important to distinguish between bulk and non-bulk packages.
Under 49 CFR 171.8 non-bulk packaging is defined as packaging which has:
- A maximum capacity of 450-liters (119-gallons) or less as a receptacle for a liquid
- A maximum net mass of 400-kilograms (882-pounds) or less and a maximum capacity of 450-liters (119-gallons) or less as a receptacle for a solid
- A water capacity of 454-kilograms (1,000-pounds) or less as a receptacle for a gas as defined in 49 CFR 173.115
Under 49 CFR 171.8, a bulk package is defined as a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous waste materials are loaded with no intermediate form of containment and which has:
- A maximum capacity greater than 450-liters (119-gallons) as a receptacle for a liquid
- A maximum net mass greater than 400-kilograms (882-pounds) and a maximum capacity greater than 450-liters (119-gallons) as a receptacle for a solid
- A water capacity greater than 454-kilograms (1,000-pounds) as a receptacle for a gas as defined in 49 CFR 173.115
While the DOT guidelines for properly labeling and marking non-bulk and bulk containers are similar, they are not the same. This document outlines the rules for non-bulk packaging.
The DOT reference to a label is very specific. Labels refer to the diamond-shaped hazmat logos placed on non-bulk containers, and resemble bulk container placards. Everything else on a non-bulk package is a marking.
The design and size of labels are based on international standards and are used to identify the hazards within the container. Each diamond (square-on-point) label measures at least 100mm (4" x 4") on each side as prescribed in 49 CFR 172.407(c)(1).
DOT Hazardous Waste Label Examples:
The proper placement of labels is important. Labels must appear in their entirety because the specified size, print style, border, width, and color of labels. Labels should be located near any markings and on the same surface. Labels should not be placed on the bottom of containers. They should always be visible.
If the waste has multiple hazards associated with it multiple labels should be displayed next to each other. The DOT recommends a six- inch space (15 cm) between labels. The label designating the primary hazard should be above and to the left of the label designating the subsidiary hazard.
Whenever hazardous material packages are overpacked, the inner containers must be properly labeled. The same applies to the overpack container.
Marking is a critical process in preparing hazardous materials for transportation. A marking on a hazardous materials package contains important information about the identification and dangers of the hazardous material. While there is no standardized hazardous waste marker format, both the DOT and EPA have specific marking requirements.
While there is no standardized hazardous waste marking format, the following general guidelines should be followed when placing markings on hazardous packages:
- Markings must be durable
- Markings must be in English
- Markings must be printed on or affixed on the surface or on a label, tag or sign
- Markings must be displayed on a contrasting color background
- Markings must not be obscured or covered up by other labels or attachments
- Markings must not be located next to any other markings (such as advertisement) that would limit their effectiveness
As mentioned above with the labeling requirements, whenever hazardous material packages are overpacked, the inner containers must be properly marked. The same applies to the overpacking.
There are five components of a DOT marking on a non-bulk package.
- Proper shipping name and identification number
- Technical name (if required)
- Special permit number
- Consignors or consignees name and address
- Special hazard warning
This information can be found in the hazardous materials table, 49 CFR 172.101. If the material is considered to be a hazardous waste, the word waste must be included with the proper shipping name. The format for properly displaying the shipping name for a hazardous waste is:
Waste (shipping name), (hazard class), (UN or NA number), (packing group)
Example: Waste Acetone, 3, UN1090, PGII
If the shipping name being used is a non-chemical specific shipping name, a technical name(s) is required for additional clarification. A non-chemical specific shipping name, as defined in 49 CFR 172.203(k), can be easily identified by the shipping name. Any shipping name that ends in N.O.S. (not otherwise specified) must be marked with the technical name(s) in parentheses in association with the proper shipping name. The technical name should correspond to the hazardous ingredients of the waste, which can be found on the Material Safety Data Sheet (MSDS).
Example: Waste Flammable Liquids, n.o.s. (Xylene, Toluene), 3, UN1993, PGII
Occasionally, hazardous materials may be placed inside a package, which was issued under a special permit by the DOT. If a special permit package is used, the container should be marked DOT-SP followed by the special permit number assigned by the US DOT.
The consignor is the party offering a hazardous material shipment for transportation. The consignee is the party receiving the hazardous material shipment.
When offering a hazardous material, which has a special hazard (e.g inhalation hazard, marine pollutant), the shipper must indicate this hazard on the marking.
Along with the hazardous waste marking requirements, there may be addition markers that are required. For example:
This marking is the package-orientation marking. It is applied to any package which holds inner containers of liquid hazardous materials. Inner packaging may be non-specification containers made of glass or earthenware, plastic or metal.
All packages having inner packages containing liquid hazardous materials must be packed with their closures upward and legibly marked with package-orientation arrows on two opposite vertical sides and with the arrows pointing in the correct upright direction. Arrows for purposes other than indicating proper package orientation may not be displayed on a package containing a liquid hazardous material.
The EPA requires certain information to be shown on containers of 110 gallons or less used in transportation. This information is listed below.
The following statement must be included on non-bulk packages: HAZARDOUS WASTE: FEDERAL LAW PROHIBITS IMPROPER DISPOSAL. IF FOUND, CONTACT THE NEAREST POLICE, OR PUBLIC SAFETY AUTHORITY, OR THE U.S. ENVIRONMENTAL PROTECTION AGENCY.
This is the same as the consignors address.
This is a twelve-digit number assigned by the EPA to each hazardous waste generator. It is also included on the hazardous waste manifest.
This is a five-digit number which is assigned by the generator. It is unique for each shipment.
This date is determined by the generator. It is the date that the generator first placed a hazardous waste inside the package. There are time limits related to the amount of time a generator can accumulate hazardous waste at its site. Consequently, this date is very important.
In order for a hazardous material to be classified as a waste, it must carry an EPA waste code. Waste codes provide more information regarding the specific hazards associated with the waste. For more information on identifying the proper waste code, refer to 40 CFR 261.
Example Hazardous Waste Marking:
- Hazardous warning statement
- Generator name and address
- Generator EPA ID number
- Accumulation start date
- EPA waste codes
- Manifest document number
- Proper shipping name, technical name, special hazard warning (if applicable) and DOT special permits (if applicable)
In addition to the federal marking requirements, there may also be state or local requirements that apply. Contact your state EPA officials to find out if there are any additional requirements.
49 CFR 172.101 Subpart B, Purpose and use of hazardous materials table and Table of Hazardous Materials .
49 CFR 172.102, Special provisions.
49 CFR 172.300 Subpart D, Marking and Applicability.
49 CFR 172.400 Subpart E, Labeling.
49 CFR 172.400(b), General Labeling Requirements Table.
49 CFR 172.402, Additional labeling requirements.
49 CFR 173, Definitions, Classifications, Packing Group Assignments and Exceptions for Hazardous MaterialsClass 1 and Class 7.
40 CFR 260, Hazardous Waste Management System
Quick Tips #155: Performance-Oriented Packaging Standard
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The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.
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