Overview
Waste containers are not appropriately labeled (chemical name and indication that the material is no longer useable for its intended purpose).
- Our labeling instructions are intended to exclude laboratory staff from RCRA training requirements.
- While laboratory staff are knowledgeable of chemicals used, they are not qualified/trained to make a RCRA waste determination.
- Waste containers must be sufficiently labeled to support a waste determination by EHS staff.
RCRA training is not required for personnel whose hazardous waste management activities are limited to working in or near satellite accumulation areas (SAA). Therefore, EHS labeling and container management instructions allow the laboratories to function as satellite accumulation areas relieves us from the burden of training every person on campus to RCRA standards. At a minimum, there are two elements to proper labeling of waste containers in Satellite Accumulation Areas (e.g., laboratories):
- Chemical identity, and
- Wording to indicate that the material is no longer usable for its intended purpose.
The label must have enough information to enable EHS staff to make a waste determination and assign appropriate codes. The major regulatory source for this category is Title 128 of the Nebraska Administrative Code or NAC.
Citations and Related Resources