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Waste labels: Try a short and sweet audit

If hazardous and/or universal wastes are a part of your operation, one of your concerns, among others, will be proper labeling. Take this checklist with you next time you walk through your site to see if you’ve nailed these requirements:

_____ Is each hazardous waste container of 119 gallons or less marked with a “Hazardous Waste — Federal law . . .” label in accordance with 49 CFR 172.304? (40 CFR 262.32(b))

_____ Is each accumulation container labeled “Hazardous Waste”? (40 CFR 262.34(a)(3))

_____ Is each accumulation container labeled with the date accumulation began? (40 CFR 262.34(a)(2))

_____ Are satellite accumulation containers marked “Hazardous Waste” or with other words that identify the contents? (40 CFR 262.34(c)(2))

_____ Are DOT marking, labeling, and placarding requirements for shipments of hazardous waste followed in accordance with 49 CFR 172? (40 CFR 262.31-.33)

_____ Are “No Smoking” signs posted where there’s a hazard from ignitable or reactive waste? (40 CFR 264.17)

_____ Are universal waste batteries or their containers labeled/marked as specified in the regulation? (40 CFR 273.14 and .34)

_____ Are universal waste lamps or their containers labeled/marked as specified in the regulation? (40 CFR 273.14 and .34)

_____ Are universal waste pesticides or their containers labeled/marked as specified in the regulation? (40 CFR 273.14 and .34)

_____ Is each piece of universal waste mercury-containing equipment or its container labeled/marked as specified in the regulation? (40 CFR 273.14 and .34)

_____ Are universal waste mercury-containing thermostats or their containers labeled/marked as specified in the regulation? (40 CFR 273.14 and .34)

_____ Are containers of used, broken cathode ray tubes labeled/marked as specified in the regulation? (40 CFR 261.39(a)(2))

_____ Are containers/tanks of used oil labeled/marked “Used Oil”? (40 CFR 279.22)

Note: This checklist may not contain “all” waste labeling or marking requirements. Also, your state may have tougher rules.

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