waste generators to identify the hazards of 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, which
could put workers, waste handlers, emergency
responders and visitors at serious risk.
To resolve this issue, the Final Rule stipulates that
container and tank labels must now indicate the
hazards of such containers’ contents in numerous
affected areas. These include areas for waste
generator satellite or central accumulation; transfer
facilities consolidating hazardous wastes from
different generators; and generator container/tank
storage areas at treatment, storage, and disposal
facilities.
Fortunately, the Final Rule allows
ample flexibility in how to comply
with this new provision.
For drip pad and containment
buildings, the generator can keep this
information in logs or records near
the accumulation unit.
Waste generators can indicate the
hazards of the container’s contents
using any of several established
methods such as DOT hazard
communication, OSHA hazard
statement or pictogram, NFPA
chemical hazard label, or RCRA
characteristic.
Examples of how to indicate the
hazards include (but are not limited to):
18 SZM Magazine • February ‘19