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Important Hazardous Waste Labeling Information

To comply with Title 22 of the California Code of Regulations (CCR), hazardous waste containers must be marked with specific information. Generally, hazardous waste containers must be labeled with the following information during accumulation and storage: [22 CCR §66262.34(f)]

The words "HAZARDOUS WASTE";
The accumulation start date for the waste in the container;
Composition (e.g. used oil; acetone 40%, toluene 60%; etc.) and physical state (i.e. solid, liquid, etc.) of the waste;
Hazardous properties (i.e. flammable, corrosive, reactive, toxic) of the waste;
Name and address of the facility generating the waste.

The easiest way to comply with these requirements is to complete one of the California hazardous waste labels distributed by label suppliers.

Standard Federal Hazardous Waste Label

Standard hazardous waste label includes all the information necessary for marking a container in compliance with the EPA regulations in 40CFR part 262 and 49CFR part 172.300. Labels measure 6" x 6" and are printed on heavyweight coated paper or exterior grade vinyl. Sold in packs of 100. Use in all states but California and New Jersey.

California Hazardous Waste Label

California hazardous waste label includes all the information necessary for marking a container for transport in California in compliance with the EPA regulations in 40CFR part 262 and 49CFR part 172.300. Labels measure 6" x 6" and are printed on heavyweight coated paper or exterior grade vinyl. Sold in packs of 100. Label helps comply with California require-ments to classify Hazardous Properties and Physical State.

New Jersey Hazardous Waste Label

New Jersey hazardous waste label includes all the information necessary for marking a container for transport in New Jersey in compliance with the EPA regulations in 40CFR part 262 and 49CFR part 172.300. Labels measure 6" x 6" and are printed on exterior grade vinyl. Sold in packs of 100. Use for New Jersey, which requires a state manifest number.

NON-RCRA Hazardous Waste Label

Non-RCRA Regulated waste label includes all the information necessary for marking a container of unregulated waste. Labels measure 6" x 6" and are printed on heavyweight coated paper or exterior grade vinyl. Sold in packs of 100.

NON-Hazardous Hazardous Waste Label

Non-hazardous waste label includes all the information necessary for marking a container of solid waste. Labels measure 6" x 6" and are printed on heavyweight coated paper or exterior grade vinyl. Sold in packs of 100.

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Standard Waste Label	California Waste Label	New Jersey Waste Label	Non-RCRA Regulated	Non-Hazardous

Hazardous Waste Labeling

When you determine that an item is hazardous waste, you must fill out and attach a Hazardous Waste Label to the waste container. The Hazardous Waste Label identifies the waste generator and the contents of the container, provides information on the hazardous characteristic(s) of the waste, and establishes the beginning waste generation date.

Each primary waste container must have a Hazardous Waste Label attached, indicating the composition of the waste in that container. A manufacturer's label does not serve this purpose, even if proper hazard information is on the label. This is often the first compliance issue noted by inspectors.

All entries on the Hazardous Waste Label must be legible. Make entries with a permanent marker or a pen containing permanent ink. Do not use pens with water-soluble ink or pencils to fill out Hazardous Waste Labels. For large primary waste containers such as carboys, affix the Hazardous Waste Label to an area of the container that is easily visible for inspection and emergency response purposes. A waste container too small for a label can be placed in a zip-lock plastic bag with a Hazardous Waste Label affixed to the bag.

Complete the Contents section of the Hazardous Waste label using one of the following three approaches:

By chemical name. If the material is a mixture, provide concentrations of all constituents, including nonhazardous constituents. This is required, in part, because some nonhazardous constituents are important in determining off site recycling, treatment, or disposal options for your waste. If this information will not fit on the Hazardous Waste Label, provide a more generic description indicating the 2 or 3 most prominent constituents that make the waste hazardous and attach a Hazardous Waste Accumulation Log or other document listing all constituents of the waste.
By manufacturer and specific product (for example, trade name or number, catalog number, etc.), including the predominant hazardous materials listed in the MSDS for the specific product. Chemical identification information of manufactured products may also be found in the "Aldrich Catalog of Fine Chemicals," the "NIOSH Registry of Toxic Effects of Chemical Substances," and "The Merck Index: An Encyclopedia of Chemicals, Drugs, and Biologicals."
By complete generic description of the material, only if the material is a mixture with a well-known standard composition. The description should list the major constituents that cause the waste to be hazardous, and should indicate whether the material is new, has exceeded its shelf life, is spent, etc. If the material is a process waste, such as a cleaning agent or an etching bath, list all of the potential contaminants from the process in addition to the known constituents—for example, "chromic acid dip-tank waste with copper." For machine coolants, identify the metals for which the coolants were used.

The generic description must be sufficiently complete to adequately characterize the waste material. For example, "photochemicals" is insufficient because a wide variety of chemicals are used in photoprocessing. The description must be more specific, such as "alkaline photo developer" or "photo fixer with chromate bleach." The appropriate description makes a big difference in this example, because these two wastes would have different disposal requirements.

Each waste container used for multiple types of wastes (e.g., more than one type of solvent) should have attached to it a record of waste accumulation (for example, a Hazardous Waste Accumulation Log; see Figure H-3). Each time you place waste in a container, enter the date, your initials, and the type and amount of waste being added. You will use this information to prepare a summary description of the container contents for the Hazardous Waste Disposal Requisition. In addition, the Waste Management Group will use your faxed Accumulation Logs to designate appropriate codes for your waste. If Accumulation Logs or other supporting documentation are not available, your waste may require analysis at a certified laboratory at your expense before it can be picked up.

If you generate wastes such as oily paper towels while performing repetitive cleaning operations at your bench, you may accumulate your wastes in a large zip lock plastic bag with a Hazardous Waste Label attached. The Accumulation Start Date on the label must be filled in with the words "Daily Accumulation," and you must empty the contents into a nearby SAA at the end of each working shift.

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