Overview
Collection containers are not closed.
One of the primary causes of notices of violations for noncompliance with the hazardous waste regulations is that satellite and 90-day hazardous waste containers are not closed. A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste.
Previously, we saw one example of a container with a broken lid, which would be appropriately cited under this checklist item. Other common situations where this checklist item is cited are shown in Exhibit A - D , such as open flasks, beakers, and funnels.
So, you may be wondering if this checklist item should be cited for containers that are unlabeled (therefore you don’t know if it is a waste material) and for containers holding a waste that you know is not regulated under RCRA. The answer is maybe.
Take the example of EHS-provided containers for “waste ethidium bromide gels”. These containers can be open because EHS has a documented waste determination on file indicating that the material is not RCRA-hazardous waste. This checklist item would not be cited in this and similar situations.
Contrast that to an unlabeled container. In most cases, you should determine through interview with lab staff if the chemical in the container is spent. If it is, then this checklist item as well as checklist item WAS01 would be cited.
If it is not spent and is a transient container, then no citation would be applicable. If it is not spent and is not a transient container, then CHE04 (chemical containers, including compressed gas cylinders are not adequately labeled) would be cited. If you find a situation like this and it appears appropriate, take the time to explain the concept to laboratory staff and have them correct the deficiency before leaving the lab.
Citations and Related Resources