Dating Hazardous Waste Containers

Posted on 3/27/2012 by James Griffin

Q. One of the more common ways to manage hazardous waste is to temporarily accumulate hazardous waste in 55-gallon drums or other containers at or near waste-generating processes in satellite accumulation areas. Then, once the containers are full, the waste is moved to a central accumulation area for a few months before shipping it to an authorized facility for treatment, long-term storage, or disposal.
In addition to the words “Hazardous Waste,” generators must mark each container with “the date upon which each period of accumulation begins…” [40 CFR 262.34(a)(2)]. But which date must they mark?
A. A hazardous waste container used like this can have up to four important dates in its lifecycle, and as a generator it is important to keep track of them. But, not all of them need to be marked on the container. And, not all of them are clearly called out in the regulations.
  1. Satellite Accumulation Start Date—Keeping track of when a container first started holding hazardous waste is important, but nothing in 40 CFR requires you to mark this date on the container. Keeping track of this date, either by marking the container or keeping written records, will help you keep an accurate count of the amount of hazardous waste you generate each calendar month and year. Some State/local waste management authorities discourage or prohibit generators from accumulating hazardous waste in satellite areas for excessive periods, thus recording the first date of satellite accumulation can be necessary to forestall any citations.
  2. Satellite Accumulation End Date—This is a date that you must mark on a container. When a generator accumulates an excess of hazardous waste (55 gallons for most wastes, 1 quart for acutely hazardous wastes) in a satellite accumulation area (SAA), “the generator must mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating.” Afterwards, the generator has three days to either transfer the marked waste to a central accumulation area or get it offsite and on its way to an authorized treatment, storage, or disposal facility. [40 CFR 262.34(c)(2)]
  3. Central Accumulation Start Date—This is another date you must mark on a container. When you transfer a waste container to a central accumulation area (CAA), either from a SAA, an inventory, or directly from a waste-generating process, you must mark the container with “the date upon which each period of accumulation begins…” [40 CFR 262.34(a)(2)] For a container transferred from a SAA, this accumulation start date may be up to three days after you reached the 55-gallon limit in the satellite area.
  4. Manifest Date—Depending on your generator status and situation, you may accumulate hazardous waste in a central accumulation area for up to 90, 180, or even 270 days. Before this time limit is up, a generator must either ship the waste to an off-site treatment, storage, or disposal facility or treat the waste to render it non-hazardous. This time limit is measured in calendar days from the time the waste was first managed in a central accumulation area under the 90- or 180-day rules. If generators keep storing their waste for more than 90 (or 180 or 270 days), then they are an unpermitted storage facility and must begin complying with all of the requirements in 40 CFR Part 265 and get a storage permit. [40 CFR 262.34(b)]

Tags: hazardous, manifests, RCRA, waste

Find a Post

Compliance Archives

Lion - Quotes

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.

Francisco Gallardo

HES Technician

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs.

Neil Luciano

EHS Manager

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!

Henry Watkins

Hazardous Waste Technician

Download Our Latest Whitepaper

Tips to identify and manage universal waste under more-stringent state regulations for generators and universal waste handlers in California.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.