[ID] => 10585
[post_author] => 34
[post_date] => 2019-02-08 12:17:47
[post_date_gmt] => 2019-02-08 12:17:47
[post_content] => In order to enhance safety and improve environmental protection, the US Environmental Protection Agency’s (EPA) Hazardous Waste Generator Improvements rule, which took effect in May 2017, requires waste generators to identify shipments. This involves the use of the words ‘hazardous waste’ on documentation, along with a description of the container’s hazards and the date the accumulation started on each container.
Previous labelling regulations under the Resource Conservation and Recovery Act (RCRA) did not require waste generators to identify the hazards of waste accumulated in containers, tanks, drip pads and containment buildings. This resulted in a failure to communicate risks associated with wastes being accumulated or stored in different locations, which could put workers, waste handlers, emergency responders and visitors at serious risk.
The Hazardous Waste Generator Improvements rule addresses this gap in coverage by stipulating that container and tank labels must now indicate the hazards of such containers’ contents in numerous affected areas. These include areas for waste generator satellite or central accumulation; transfer facilities consolidating hazardous wastes from different generators; and generator container/tank storage areas at treatment, storage, and disposal facilities.
The rule is not prescriptive and gives generators some flexibility in achieving compliance. For instance, for drip pad and containment buildings, the generator can keep the required information in logs or records near the accumulation unit.
In addition, waste generators can indicate the hazards of a container’s contents in one of several ways, including the use of established methods such as US Department of Transportation (DOT) hazard communication, Occupational Safety & Health Administration (OSHA) hazard communication standards for statements and pictograms, the National Fire Protection Association’s (NFPA) chemical hazard label, or RCRA characteristics.
Examples of how hazards can be indicated include – but are not limited to – the following:
- The words of the applicable hazardous waste characteristics (e.g. ‘ignitable’, ‘corrosive’, ‘reactive’, ‘toxic’, etc)
- Hazard communication consistent with the DOT requirements in 49 CFR part 172 subpart E (labelling) or subpart F (placarding)
- A hazard statement or pictogram consistent with the OSHA Hazard Communication Standard at 29 CFR section 1910.1200, or
- A chemical hazard label consistent with the NFPA code 704.
According to EPA, the Hazardous Waste Generator Improvements rule provides waste generators some economic and environmental benefits. For example, it provides flexibility to very small quantity generators (VSQGs) that generate 100 kg or less of hazardous waste per month to ship their waste to a large quantity generator (LQG) under the control of the same company.
CLASSES OF COMPLIANCE
The rule also addresses episodic generation of hazardous waste. This occurs when a non-routine event, such as a product recall, results in a smaller generator – a VSQG or small quantity generator (SQG) – generating an atypical amount of hazardous waste in one month, triggering more stringent generator regulations. Under the Final Rule, a generator can maintain its usual generator category during a non-routine event and avoid the increased requirements of a higher generator status.
RCRA waste codes must be placed on the containers before shipping hazardous waste off site to an RCRA permitted treatment, storage and disposal facility, but do not need to be applied before that time. An electronic system, such as a bar code system, is acceptable as long as the RCRA waste code(s) are tied to the specific container.
Some states – Alaska and Iowa, for instance – are not authorised for the RCRA programme; however, they will be required to comply. If state laws need to be changed to allow for implementation of the new requirements, there is a deadline of 1 July 2019.
STICKABILITY IS VITAL
While waste generators have various ways by which they can communicate the hazard of a container’s contents, there are some basic common requirements. For instance, hazardous waste generator labels must also be very durable and remain attached to the container.
As a result, when it comes to printing EPA Hazardous Waste Generator compliant labels, one of the easiest ways to become compliant is for companies to use their existing printers along with appropriate printing software. For the many chemical manufacturers, distributors and end users that are already complying with OSHA’s HazComm standard for Globally Harmonised System (GHS) labels, this means using GHS labels along with software that utilises new templates specific to the hazardous waste rules.
As an example, companies can use UltraDuty GHS Labels by Avery, a leading label brand in the industrial and office markets. Unlike typical labels, these GHS labels are industrial-grade labels designed to be chemically resistant, tear resistant, abrasion resistant, and constructed with a marine-grade adhesive that is waterproof and passes a 90-day seawater submersion adhesion test.
Using the company’s Design & Print Online software, available at www.avery.com/ghs
, employees can create, customise and print their own hazardous waste labels at their desk from pre-designed, EPA-compliant templates. Most employees find such a process intuitive, since it resembles creating an office document from pre-designed templates.
Printed labels with handwritten (Accumulation Start Date, EPA Waste Codes) or marked hazardous properties (flammable, corrosive, toxic, reactive; along with GHS pictograms) are also acceptable. Avery’s pre-printed, write-on Hazardous Waste Accumulation labels comply with this requirement.
The pre-printed labels allow easy selection of the applicable GHS pictograms or hazardous properties along with accumulation start data and content composition. These help to simplify proper labelling and are compatible with ball point pens and permanent markers. Such labels can work for a variety of hazardous waste generators, including VSQGs, SQGs, LQGs and sub-part K (Academic Laboratories).
[post_title] => Hazwaste: Labelled with care
[post_status] => publish
[comment_status] => open
[ping_status] => open
[post_name] => hazwaste-labelled-care
[post_modified] => 2019-03-07 11:50:04
[post_modified_gmt] => 2019-03-07 11:50:04
[post_parent] => 0
[guid] => https://www.hcblive.com/?p=10585
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