Examples of how to indicate the hazards include (but
are not limited to):
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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.
18 SZM Magazine • January ‘19
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The words of the applicable hazardous waste
characteristic(s) (i.e., ignitable, corrosive,
reactive, toxic);
Hazard communication consistent with the DOT
requirements at 49 CFR part 172 subpart E
(labeling) or subpart F (placarding);
A hazard statement or pictogram consistent with
the OSHA Hazard Communication Standard at 29
CFR section 1910.1200
A chemical hazard label consistent with the NFPA
code 704.
According to the EPA, the Final Rule provides waste
generators some economic and environmental
benefits. For example, it provides flexibility to very
small quantity generators (VSQGs) that generate 100
kilograms or less of hazardous waste per month to
ship their waste to a large quantity generator (LQG)
under the control of the same company.
The Final Rule also addresses episodic generation of
hazardous waste. This occurs when a non-routine
event, such as a product recall, results in a smaller
generator – a VSQG or small quantity generator (SQG)
– generating an atypical amount of hazardous waste
in one month, triggering more stringent generator
regulations. Under the Final Rule, a generator can
maintain its usual generator category during a non-
routine event and avoid the increased requirements
of a higher generator status.
The RCRA waste codes must be placed on the