containers before shipping hazardous waste off site
to a RCRA permitted treatment, storage and disposal
facility, but do not need to be applied before that time.
An electronic system, such as a bar code system, is
acceptable as long as the RCRA waste code(s) are tied
to the specific container.
States not authorized for the RCRA program like
Alaska and Iowa are currently required to comply.
RCRA authorized states will be required to adopt
the more stringent portions of this final rule by July
1, 2018. If a state law must be changed for adoption
then the deadline is July 1, 2019.
Labeling Options for EPA Hazardous Waste
Generator Compliance
While indicating the hazards of the container’s
contents in various permissible ways, hazardous
waste generator labels must also be very durable and
remain attached to the container.
So when it comes to printing EPA Hazardous Waste
Generator compliant labels, one of the easiest ways
to become compliant is for companies to use their
existing printers along with appropriate printing
software.
For the many chemical manufacturers, distributors,
and end users that are already complying with
Globally Harmonized System” (GHS) labels for OSHA,
this means using GHS labels along with software that
utilizes new hazardous waste specific templates.
As an example, companies can use UltraDuty GHS
Labels by Avery, a leading label brand in the industrial
and office markets. Unlike typical labels, these GHS
20 SZM Magazine • January ‘19
labels are industrial-grade labels designed to be
chemical resistant, tear resistant, abrasion resistant,
and constructed with a marine-grade adhesive that is
waterproof and passes a 90-day seawater submersion
adhesion test.
Using the company’s Design & Print Online Software,
available at www.avery.com/ghs, allows employees
to create, customize, and print their own hazardous
waste labels at their desk from pre-designed, EPA
compliant, templates. Most employees find such a
process intuitive, since it resembles creating an office
document from pre-designed templates.