All generators, transporters, and commercial handlers of hazardous waste should be aware of the Department of Transportation’s (DOT’s) rules on the containerization and storage of toxic waste. Transporters, along with generators, must comply with the rules or face legal consequences.
DOT regulations are meant to ensure safety and accountability when handling hazardous materials. And they also coincide and work in conjunction with the Environmental Protection Agency (via the Resource Conservation and Recovery Act, or RCRA) and its guidelines.
But once you are familiar with these regulations, you will be better suited to make the best choices for your business, including who you want to truck or ship your waste (are they compliant with DOT’s rules?), and other decisions that can affect the bottom-line of your business (making sure to keep within legal boundaries when dealing with hazardous waste so as not to incur a fine, for one).
The labeling of hazardous waste is something that readily comes to mind when talking about the transportation of waste, as we have all seen the diamond-shaped, multi-colored placard labels on containers of toxic substances. These are DOT labels, and it is required that they must be readable, properly pronounce the hazardous nature of the waste (corrosive, flammable liquid or solid, oxidizing substance, etc.), and placed on a surface rather than the bottom of a container.
If multiple labels are necessary, then they must be within 6 inches of each other. The primary label should always be listed first, followed by any needed subsidiary labels. But having the correct label for the waste a container holds is only one of the steps.
DOT regulations also require proper “marking” (which by DOT’s definition is different than labeling). All markings must be durable in nature, not obscured by other labels, and in English. Basic marking requirements mandate that a package should read as follows:
HAZARDOUS WASTE – Federal Law Prohibits Improper Disposal. If found, contact the nearest public safety authority or the Environmental Protection Agency.
Generators name and address: [write in the business name and address]
Manifest Document Number: [write in the manifest number]
Additionally, depending on the situation and type of hazardous material, there may be more information necessary, including,
- A United Nations substance (UN) number or North American (NA) identification number, with a four-digit number which identifies the exact type and class of waste inside (not required for limited quantities),
- A description of the waste (for non-bulk packaging),
- Technical name (for non-bulk packaging), and
- The shipper’s name and address (if the waste is being shipped).
Multiple Containers and Duplicate Labels
If you’re shipping of several containers of consonant hazardous waste (as unlike or incompatible waste should under no circumstances be stored together in the same container), then a label must be affixed to the packaging to represent every class of hazardous waste that is to be stored overnight for transport.
Duplicate labeling may be required at times (and when this is so, labels must be placed on at least two sides of the container), including when,
- A package’s volume exceeds 480 gallons,
- Any non-bulk package contains radioactive substances,
- A portable tank is less than a 1,000 gallon-capacity, and
- Freight containers or aircraft unit load devices have a volume of approximately 480 gallons.
If you would like to know more about the Department of Transportation’s regulations on storing and transporting waste, we are more than happy to assist you in any way possible. Call Hazardous Waste Experts at 800-936-2311 or click here to email us.