Safety Zone Magazine January 2019 | Page 22

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.