Hazardous Waste Program- Containers

MoDNR Topics

Containers

From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

Aug. 29, 2007

What About Container Weight?

Question: When determining the weight of hazardous waste to be shipped,
do you include the weight of the container? Or just the waste inside the
container?

Answer: If you are trying to calculate your hazardous waste generator
status, then the container itself is not considered a hazardous waste so
it's weight does not need to be counted towards your hazardous waste
generation level (i.e. Large, Small, or Conditionally Exempt). Your
business may track the weight of the hazardous waste itself, however you
should realize that transporters typically include the entire weight of
the item, packaging and all, so that may be reflected on the manifest. See
EPA's guidance on this subject.

If you subtract container weight from the entire weight transported to
track you hazardous waste generation rate, be aware that any new container
you purchase may not weigh the same amount as your current containers. For
instance, steel drums made today usually weigh less than their
predecessors but still meet the same strict U.S. Department of
Transportation performance requirements for transport due to improved
design. If you change containers, be sure to change your calculation for
determining the weight of the hazardous waste in the container.

If you choose to use volume to track your hazardous waste generation, you
must know the specific gravity of each waste stream to make sure you are
managing your waste in accordance with the correct generator level. You
can use volume and specific gravity to calculate the weight of the waste.
First, multiply the specific gravity of your liquid by the density of
water (8.33 lbs/gallon) to find the density of the liquid. Then multiply
the density of the liquid by the volume of the liquid to equal the weight
of the waste. For instance, a 55-gallon container of toluene has a
specific gravity of 0.866. Multiply 0.866 by the density of water, 8.33
lbs/gallon. The resulting density is 7.21 lbs/gallon. Multiple 7.21
lbs/gallon by 55 gallons and the result is the weight of the toluene in
pounds (396.55 pounds). You can usually find the specific gravity on the
Material Data Safety Sheet or, if your waste is a mixture, by using
knowledge and the specific gravities of the constituents.

If you decide to dispose of a hazardous waste container, then you must
make a hazardous waste determination on the container itself. At the time
the container is destined for disposal and is determined to be a hazardous
waste, then it will count towards your hazardous waste generation level.
Often generators of acute wastes choose to dispose of the associated
container and thus the entire weight of both the acute hazardous waste and
the container would be considered hazardous. For more information on the
definition of empty or acute hazardous waste, please review our previous
listserv on the subject at /env/hwp/enf/empty.htm

To correctly fill out the Uniform Hazardous Waste Manifest, the weight of
the entire container, waste, packaging, etc. must be recorded on the
manifest. The weight including container is also used to determine if the
hazardous waste equals or exceeds the reportable quantity. For more
information on the Uniform Hazardous Waste Manifest, visit
/env/hwp/enf/manifest-rules.htm.

May 31, 2007

Label Placement

Labels are used to identify the hazard class of material in containers and
packages offered for transport. Because the labels are used to
communicate important information, it is vital that they are easy to
locate. In general, to meet U.S. Department of Transportation
requirements, labels must be: on a surface other than the bottom of the
package AND be located near and on the same surface of the package as the
marking of the proper shipping name. If your hazardous waste requires
multiple hazard labels, then they must be placed within 6 inches (150 mm)
of one another. The primary hazard label is listed first in column 6 of
the 49 CFR 172.101 Hazardous Materials Table, and any subsidiary label (if
necessary) is listed next.

Mixed and Consolidated Packaging

If your business consolidates shipments - puts multiple, compatible
hazardous wastes together for storage or transport - then you must label
the packaging, outside container, or overpack with every hazard class of
the waste it holds. As always, never put incompatible hazardous waste
together. You may find a list of incompatible hazardous wastes in
Appendix V of CFR 265.

Duplicate Labeling Is Required When

the package or overpack has a volume of 1.8 cubic meters (64 cubic feet
or approximately 480 gallons)
any non-bulk package containing radioactive material
each DOT 106 or 110 multi-unit tank car tank (display on each end)
a portable tank of less than 3,785 L (1,000 gallons) capacity
freight containers or aircraft unit load devices having a volume of 1.8
cubic meters (64 cubic feet or approximately 480 gallons) but less than 18
cubic meters (640 cubic feet).

If your business uses these types of containers for hazardous waste
storage or transport, labels must be displayed on at least two sides of
the container.

Marking Satellite Containers

You have several options when marking hazardous waste stored in satellite
accumulation areas. According to 10 CSR 25-5.262(2)(C)3, hazardous waste
containers in satellite accumulation areas must be marked with "Hazardous
Waste," the EPA waste code, shipping description, description of contents
("waste toluene"), or other words that identify the contents of the
containers. Also, unlike hazardous waste in 90 or 180-day storage,
hazardous waste in satellite accumulation areas does NOT need to be
labeled or marked according to U.S. Department of Transportation
regulations.

Labeling or Marking Universal Waste

As with satellite containers, universal waste also has labeling options.

For mercury switches, in Missouri the label should read "Universal
Waste-Mercury Switch(es)", or "Waste Mercury Switch(es)" or "Used Mercury
Switch(es)";
For batteries, the label should read "Universal Waste-Battery(ies)", or
"Waste Battery(ies)" or "Used Battery(ies)";
For thermostats, the label should read "Universal Waste-Mercury
Thermostat(s)", or "Waste Mercury Thermostat(s)" or "Used Mercury
Thermostat(s)";
For lamps, the label should read "Universal Waste-Lamp(s)", or "Waste
Lamp(s)" or "Used Mercury Lamp(s)";
For pesticides, the label should read "Universal Waste-Pesticide(s)", or
"Waste Pesticide(s)".

Remember, hazardous waste pesticides may only be managed as a universal
waste as long as they are sent to a Missouri approved universal waste
pesticide collection program, to a Certified Resource Recovery Facility,
or to a Universal Waste Destination Facility.

April 23, 2007

Labeling and Marking

Throughout the next few listservs we will discuss labeling and marking requirements for your hazardous waste. Small and Large Quantity Generators that store hazardous waste in containers must place and maintain the following information on each container from the time waste is first placed in the container:

Markings - container must display the wording as it appears below:

"HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, Contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
Generator's Name and Address: (fill in your company's name and complete address including city and state)
Manifest Document: (fill in manifest document number when the container is prepared for shipment offsite)"

Accumulation Date - the day, month, and year that you first placed waste in the container.
Labeling - In Missouri, each container must be labeled with the appropriate U.S. Department of Transportation hazardous material warning label commonly known as the U.S. Department of Transportation (US DOT) diamond sticker. Examples include "flammable liquid," "corrosive," and "poison".

Labels and markings must be durable. Labels must not be obscured by other markings or covered by attachments. If reusing a container, make sure all old labels or markings are removed or painted over to avoid confusion. Move, or orient, containers so that both employees and inspectors can see all important information. This helps ensure that hazardous waste is accounted for and is not stored in excess of the time limit.

If the accumulation date on the container is handwritten, be certain that it is legible and clear. Be consistent in the date format that you use. Pick one format (i.e. month/day/year or year/month/day) and stick with it.

For more information on the U.S. DOT. Chart 12 Hazardous Materials Marking Labeling and Placarding Guide, view page 63 of the department's Hazardous Waste Management Handbook for Small Quantity Generators. Check every hazardous waste container that you have in storage and make sure that all the proper information is present and visible. Proper labels and markings help make sure your employees, emergency responders, and waste handlers, manage the waste safely and appropriately. Please review the Hazardous Waste Generator Archive Satellite Accumulation for more information on marking and labeling satellite accumulation containers.

Sept. 28, 2006

What is a hazardous waste container?

The RCRA hazardous waste regulations define a container as "any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled." The definition is broad enough to cover the many different types of portable devices that may be used to handle hazardous waste, ranging from small test tubes to 55-gallon drums to large tanker trucks.

Hazardous Waste Container Management Requirements:

All containers used to hold hazardous waste are required to be in good condition.
Containers holding hazardous waste must be closed at all times, except when adding or removing waste. Please see below for more information on closed containers.
Containers must be clearly marked with the words HAZARDOUS WASTE
Containers must be marked with the date you begin to collect waste in that container.
Waste stored must be compatible with its storage container.
Incompatible wastes must be stored separately or protected from each other by a dike, berm or wall. For example, you must keep waste alkaline cleaner segregated from spent acid to avoid a bad reaction. Please see our electronic newsletter archive on incompatible chemicals.
Containers holding ignitable or reactive waste must be at least 50 feet from the generator's property line or meet alternative requirements.
Maintain aisle space between containers to provide easy inspections and movement of personnel and equipment.
All containers and container areas must be inspected for leaks or corrosion at least weekly. Inspection records need to be kept for 3 years following the date of inspection.
Areas subject to spills must be inspected daily.
In Missouri, hazardous waste must be packaged, labeled, and marked per U.S. Department of Transportation regulations the entire time they are in storage.
In Missouri, precautions must be taken to prevent accidental ignition or reaction of ignitable or reactive waste. This includes confining smoking and open flame to specially designated locations and hanging "No Smoking" signs near ignitable or reactive waste.

Container Tips - Suggestions for Managing your Containers

Let your employees choose the type of closure device that will work best for them.
Although stacking drums is allowed, we strongly recommend placing a stabilizing material between drums and stacking no more than two drums high.
Hang your weekly inspection log on a clipboard in the storage area. When it is full, file it in your permanent records. Make sure the inspection log includes the employee's name, the date and time of each inspection, his or her observations of each inspection, and the repairs or remedial actions completed.
To avoid waste spills from destroying your label, place the label on the side of the container away from the bung. You may also wish to protect labels by applying a thin coat of varnish, covering them with clear packing tape, or enclosing them in a plastic pouch designed for that purpose.

Feb. 15, 2006

Are your hazardous waste containers closed? Open containers are frequently a compliance issue for hazardous waste generators. According to 40 CFR 265.173(a) "A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste" Properly closed containers benefit you by helping to prevent spills, reducing emissions of volatile wastes, reducing the chance for incompatible chemicals to mix, protecting ignitables or reactive wastes from possible sources of ignition or reaction and preventing contact with employees.

When evaluating whether a container is properly closed it is important to answer these two questions: Is the container vapor tight? and Is the container spill proof? If you can answer yes to both of these questions then you can consider the container closed. Unless adding or removing waste, bungs on drums must always be in place and tightly secured. Lids on other types of containers must be capable of preventing vapors from escaping and spills from occurring. Because some closures can deteriorate over time, it is important to frequently check closure equipment to make sure it continues to be functional. Don't forget that the closure requirements apply to both hazardous waste containers located in storage and in satellite accumulation areas.

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If you need further assistance, please e-mail or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.

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