Overview
Chemical name(s) of the contents
- Fully written, proper chemical name
- Acronyms and trade names – only if traceable back to a Safety Data Sheet (e.g., EDTA, H2SO4)
- Percentages for mixtures
- Is sufficient information included in the container labeling to make a waste determination?
- HMCT (Hazardous Material Collection Tag) only if information equivalent to a label
In addition to wording indicating that the material is no longer usable for its intended purpose, the content of the container must be identified uniquely and precisely. Under the chemical safety section, we discussed in detail the labeling requirements for unused or usable chemicals in containers. Do not confuse the labeling requirements of usable containers with the requirements for waste containers. The requirements are different. Acronyms are ONLY allowed on a waste container if it is referenced in the Safety Data Sheet as a name for the chemical. An example is EDTA, which is also known as Ethylenediaminetetraacetic acid. H2SO4 is another example of an acceptable abbreviation because it can’t be confused for any other chemical.
Remember the statement at the beginning of this section about enforcement discretion and varying interpretations by different regions, states, and even inspectors? This is one of those areas. We’ve had an inspector accept a container labeled as “used solvents” while another inspector cited us for a container of petroleum ether labeled as “Pet Ether.” So, our guidance is based on what we believe to be reasonable and defensible. Under this approach, a waste container must be labeled in a manner that we would be able to make a waste determination on the spot without invoking the assistance of a laboratory worker.
Most all of you are involved in the collection of waste containers from laboratories. When you are collecting these containers, a tag is already completed and you have already decided the information provided was adequate to make a waste determination. If not, you would have called or emailed the lab to get more information. In performing laboratory safety compliance surveys, you will often be seeing the containers before these are tagged for collection. In assessing conformance with this survey item, ask yourself, is this container adequately labeled or is sufficient information readily available (e.g., contents log, SDS, etc.) for you to make an accurate waste determination. If not, we have a deficiency which needs to be corrected before leaving the lab. We would expect a RCRA regulator to evaluate compliance with proper waste labeling similarly.
Obviously, the most conservative labeling would include fully-written, proper chemical name(s) and the percentage for mixtures. But there may be situations where a container is labeled as “used solvent” and that is acceptable because there is a readily apparent log that details the exact constituents. You’ll have to use professional judgment when evaluating proper labeling both in terms of chemical name and percentages. Percentages are necessary only in some situations. In other situations the percentage is irrelevant. So, you’ll have to use some professional judgment when deciding whether to cite this item as a deficiency. Remember, a waste determination is made based on concentrations of constituents or characteristics at the time of generation, not after dilution by mixing several waste streams. Generally speaking, we do not cite improper labeling for lack of percentages on a waste container label.
Use of a Hazardous Materials Collection Tag (HMCT) as a means of container labeling is acceptable only if the tag is completed with the information required for a label.