Hazardous Waste: Container Management
Violations most often-cited by EPA (and other agencies) involve containers of hazardous materials and of Hazardous Waste. Under the Resource Conservation and Recovery Act (RCRA, the main body of federal-level (EPA) regulations that govern hazardous waste) hazardous wastes must be properly managed to minimize release of the hazardous waste (or hazardous material) into the environment.
What, specifically, does this mean?
A Hazardous Waste (official EPA terminology) is any hazardous (flammable, toxic, corrosive, reactive) material that is no longer useful or wanted by the generator. Once a hazardous material is determined to be a Hazardous Waste by the generator, it must be managed as a Hazardous Waste:
The container must be compatible with its contents.
Before adding Hazardous Waste to a container, confirm that the container will be compatible with the chemicals you are adding. For example, collect corrosive Hazardous Waste in plastic or glass containers, rather than metal. Confirm the cap is compatible as well. Obtain containers for Hazardous Waste collection from EH&S.
The container must be kept CLOSED except when actively adding Hazardous Waste to the container
Open containers allow chemical vapors to enter the air; if the container falls over, Hazardous Waste will be spill out. A Hazardous Waste container with a funnel in it is OPEN. Replace the cap once material has been added to the container. Obtain special HPLC waste containers from the EH&S Office (x8988, x8978).
The container must be properly LABELED with its contents and the term “Hazardous Waste”
Use official Hazardous Waste labels from EH&S. Affix to container upon addition of the first material to the container. List all components using FULL chemical names (no abbreviations or formulas). Do NOT put a date on the label; the label is dated only once the Hazardous Waste container is moved from the Satellite Accumulation Area (SAA, the lab room in which the waste was generated) to the Main Accumulation Area (MAA, Davis 431A).
The container must be stored in secondary containment in case the primary container fails
Place the Hazardous Waste Container in a deep-sided tray (obtained from EH&S) or other container (e.g. large Nalgene beaker) to contain potential spills/releases. If liners are used, they must be changed frequently and disposed of as Hazardous Waste (as spill materials).