Overview
Abandoned chemicals are present (e.g. unlabeled/unknown/unwanted/unneeded, etc.)
Recall that a solid waste is any abandoned material and includes materials that are being stored in lieu of disposal. EPA added this element to its concept of abandoned material to prevent people from escaping hazardous waste management requirements by simply storing wastes indefinitely. EPA specifically had obsolete chemicals or products in mind when they crafted this language.
Very old or unknown chemicals could be considered waste if an inspector feels these are being accumulated or stored in lieu of disposal. In Exhibit A, it would be difficult to to argue the material contained in the metal containers are still of value with the intent of future use. "Unlabeled chemical containers" could also be cited with the notion of “How can a chemical be useful if you do not know what it is?”
The other situation that has led to inspectors citing this item is chemicals that are clearly labeled with an expiration date and which have not been tagged for disposal, particularly if the expiration date is severely lapsed. Many manufacturers will include a date reference on their label, sometimes as part of the lot number. Be alert to very old chemicals confirmed in this manner.
Bottom line – labs should tag for disposal obsolete chemicals and products, particularly if they tell you that they don’t really know why they are keeping it or what it will likely be used for. Be particularly alert to old compressed gas cylinders. They can be especially hazardous.