Overview
Collection containers are not in good condition and/or compatible with the contents.
- Directly from the hazardous waste regulations:
- “If a container holding hazardous waste is not in good condition (e.g., severe rusting, apparent structural defects) or if it begins to leak, the owner must transfer the hazardous waste from this container to a container that is in good condition…”
- “The owner must use a container made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired.”
- Be cognizant of waste containers being overfilled.
Regarding container condition and compatibility with contents, this is one of the few instances where the hazardous waste rules are very straight-forward. The regulations require that wastes be transferred to a container with good integrity if the current container shows signs of actual or potential failure, and that waste be stored in containers that are compatible with the content. These regulations pertain to all wastes, regardless of whether in a laboratory or in the EHS waste accumulation facility.
This is a good opportunity to discuss the overfilling of waste containers. The Hazardous/Radioactive Material Collection Procedures SOP states the user should allow 3-inches of headspace for 1-gallon containers and 1-inch of headspace for 5-gallon containers. If containers are overfilled and contain a volatile or semi-volatile waste, the container may crack or break during storage. This has happened, particularly when stored in the East Campus Waste Accumulation Area (WAA) during the summer. If you encounter an overfilled waste container during your audit, cite it under this checklist item, and inform the lab that they will need to remove some of the waste before EHS can pick-up the container.
Citations and Related Resources