California Generator Improvements Rule: Hazardous Waste Labels and Markings on Containers, Tanks

California DTSC has released an FAQ to help hazardous waste generators comply with revised and re-organized State regulations in effect as of July 1, 2024.

FAQ #5 on the California Generator Improvements Rule webpage answers questions about three new tank labeling and marking requirements, a minor change to simplify rules for labeling containers, and examples of acceptable marking/labeling.

View the FAQ on DTSC's website.

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California Generator Improvements Rule FAQ 

Labeling and marking – 66262.16 (b)(4)(B) and 66262.17 (a)(5)(B)

1. What are the new tank labeling and marking requirements?

There are three new tank labeling and marking requirements:

1. Generators must mark or label their tanks with an indication of the hazards of the contents (i.e. the applicable hazardous waste characteristic(s) or hazard communication consistent with the Department of Transportation regulations, Occupational Safety and Health Administration hazard communication standards, or chemical hazard labels consistent with the National Fire Protection Association).

2. Generators must use inventory logs, monitoring equipment, or other records to demonstrate that hazardous waste has been emptied within the applicable time period (i.e., either 90 days for LQGs or 180 days for SQGs) of first entering the tank if using a batch process, or in the case of a tank with a continuous flow process, demonstrate that estimated volumes of hazardous waste entering the tank daily exit the tank within the applicable time period (i.e. either 90 days for LQGs or 180 days for SQGs) of first entering.

3. Generators must keep inventory logs or records on site and readily available for inspection.

2. Is there a difference between the previous regulatory requirement to label a container with “statement or statements which call attention to the hazardous properties of a waste” and the GIR requirement to mark or label a container with “an indication of the hazards of the contents?”

Yes, there is a slight difference. The GIR restructured the language of the existing container labeling requirements and added the ability to use acceptable hazard indicators (DOT, OSHA, NFPA, etc.), so that the requirement is more easily understood.

3. What are some examples of acceptable labels that meet the new criteria for indicating a waste’s hazard?

The following are examples of a DOT acceptable indicator (1), OSHA haz-com indicators (2) and NFPA indicators (3).

1. 
2. 
3. 

4. How long is a generator required to retain inventory logs or records for hazardous waste tanks?

Generators must retain inventory logs or records for hazardous waste tanks for at least three years from the date the waste is first accumulated.

Lion Members: Visit Lion.com/Members for more detail about important changes to California's hazardous waste laws and regulations now that the Generator Improvements Rule is in effect. 

California Hazardous Waste Training (Title 22/RCRA)

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