Hazardous waste label requirements —
comply with EPA/RCRA regulations

Proper identification and labeling is foundational to a safety manager’s success. They help blend speed and efficiency into operations and put information front and center for workers. Often, information that directly affects health and safety.

Hazardous waste labeling is no exception.

Hazardous waste labels warn of inherent danger if not disposed of or handled properly. Missing or inadequate labeling can produce fines, adverse health effects, environmental contamination and more. RCRA regulations and EPA labeling requirements ensure labels are uniform and effective.

Let’s explore the regulations that govern hazardous waste label requirements, required text (including a hazardous waste label example) and labeling best practices.

The history — hazardous waste labeling requirements began with RCRA regulations

Hazardous waste is a subset of solid waste that may be detrimental to human health or the environment. In the United States, the Resource Conservation and Recovery Act (RCRA) gives the Environmental Protection Agency (EPA) the authority to control hazardous waste from cradle to grave.

It can take many forms from many sources, such as the byproduct of a manufacturing process or a product that you use or encounter daily, from cleaning fluids to battery acid. This makes the term “solid waste” a misnomer, as it can exist as a solid, liquid, gas or sludge.

Hazardous wastes under RCRA regulations in Title 40 CFR, Part 261 are divided into two major categories:

• Listed wastes (F, K, U and P Lists)
• Characteristic wastes (ignitable, corrosive, reactive, toxic)

Reference the EPA’s Hazardous Waste Identification Process to determine if your material in question is a hazardous waste.

The basics — text that must be displayed

For non-bulk packaging of hazardous material, the EPA’s hazardous waste container labeling requirements state that a label must include:

• The following text: “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
• Generator’s EPA identification
• Manifest tracking number

While the EPA provides specific regulatory guidelines, there is no standardized format (e.g., colors, size or text order).

The fine print — labeling requirements vary by state

RCRA regulations allow states to develop more stringent regulatory programs. After review by the EPA, states may then be able to take over responsibility for implementation. As such, it’s important for you to check with your state’s authority having jurisdiction regarding hazardous waste labeling requirements and whether further guidelines exist.