The proper handling techniques for containers of hazardous wastes are defined within the Resource Conservation and Recovery Act (RCRA) regulations. Containers that are properly selected, labeled, and handled will minimize the risk of spills that might lead to personal injury or pollution to the environment. Specific handling requirements depend on the available facilities, the volume of waste generated a month and the desired mode of hazardous waste handling and transportation.

The personnel that make decisions regarding hazardous waste containers, labeling, storage, and transportation must be trained in the regulatory requirements of RCRA, and must know who establishes and enforces those regulations in the generator's location. The applicable hazardous waste regulatory program could be operated by a regional office of the Environmental Protection Agency (EPA) or by an EPA-approved state agency. In this data sheet, only references to federal regulations are provided. However, additional or alternative state regulations may apply. All state programs have the same basic regulatory requirements as the federal program but should be consulted prior to establishing any procedures.

This data sheet addresses the generator's requirements for container type, marking, and labeling. For the purpose of this data sheet, an installation may have more than one waste-generating site. Proper preparation of hazardous wastes for off-site transport must be performed by trained personnel in accordance with the Hazardous Materials Transportation Act regulations provided in 49 CFR Subchapter C (Parts 171 through 177). Often times, the hazardous waste transporter will be responsible for providing compliance with 49 CFR 171-177.

1. Container Storage

In general, hazardous waste may be stored in accordance with one of five sets of regulatory requirements. The requirements for an "initial accumulation area" (also called a "satellite accumulation area"); the requirements of a " 90-day storage area;" the requirements of a "180-day storage area," the requirements of a conditionally exempt small quantity generator, or the requirements for a permitted treatment, storage, or disposal (TSD) facility must be satisfied for each location where hazardous waste is stored.

Fulfilling the requirements for a TSD facility is a complicated and demanding task that is far beyond the requirements for storing wastes from a single waste-generating process at an installation with multiple waste-generating sites. By comparison, the requirements for an "initial accumulation area" or a "180- or 90-day storage area" area much less complex and still provide an area that is suitable for many waste-generating situations.

The regulatory limit for accumulating hazardous waste at an "initial accumulation area" is volume-based (no more than 55 gallons allowed, in most cases), while the limit for accumulating hazardous waste at a "180- or 90-day storage area" is time-based (no longer than 180 days or 90 days of storage allowed, in most cases) but also relates to volume. Generators who generate greater than 1,000 kilograms of hazardous waste a month may only store waste on-site for 90 days or less. Generators who generate between 100 to 1,000 kilograms of hazardous waste a month may store waste on-site for up to 180 days. Generators who generate 100 kilograms of hazardous waste or less a month, in most cases ("conditionally exempt small quantity generators") do not have to meet any time limit on the storage of their hazardous wastes, container selection and labeling requirements. When the corresponding limit is reached at any type of storage area, the waste must then be transferred. Hazardous waste from an "initial accumulation area" can be moved to an on-site "90-day or 180-day storage area" or a permitted TSD facility. Hazardous waste from a "180-day or 90-day storage area" can only be moved to a permitted TSD facility.

An "initial accumulation area" must be located at or near the waste-generating activity and be under the direct supervision of the operator of the activity. In accordance with 40 CFR 262.34 (c):

• No more than 55 gallons of hazardous waste or 1 quart of acutely hazardous waste may be accumulated at an "initial accumulation area." There is no time limit on how long it takes for waste to be accumulated up to the volume limit.
• A container holding hazardous waste must always be kept closed during storage except when it is necessary to add or remove waste.
• If the container holding the waste leaks, the waste must be transferred to a new container.
• Once the volume limit is exceeded, the generator must mark the hazardous waste container with that date, and transfer that waste out of the area within 3 days.

A " 90-day storage area" must be located on site at the installation and be managed in accordance with the following requirements from 40 CFR 262.34 (a).

• Any volume of hazardous waste can be collected and stored in acceptable containers, tanks, or containment buildings (or drip pads, in the case of equipment that contains hazardous waste), providing no accumulated hazardous waste remains in storage for more than 90 days.
• A container holding hazardous waste must always be kept closed during storage except when it is necessary to add or remove waste.
• The container must not be handled in a manner that will cause it to leak.
• If the container holding the waste leaks or is not in good condition, the waste must be transferred to a new container.
• The containers must be inspected at least weekly for leaks and signs of corrosion.
• Containers holding ignitable or reactive waste must be located at least 50 feet from the installation property line.
• Containers of incompatible waste must be separated by means of a dike, berm, wall, or other structure.
• A "90-day storage area" must have preparedness and prevention equipment (i.e., communication, alarm, and fire-fighting systems in accordance with 40 CFR Part 265 Subpart C (265.30 through 37)). This subpart also covers requirements for aisle space between containers, arrangements with local authorities, access to equipment, and testing and maintenance of equipment.
• A "90-day storage area" must have a contingency plan with established emergency procedures in accordance with 40 CFR Part 265 Subpart D (265.50 through 56).
• Facilities with a "90-day storage area" must ensure personnel receive training in accordance with 40 CFR Part 265.16.
• Facilities with" 90-day storage areas" must comply with land disposal restrictions in accordance with 40 CFR Part 268.7(a)(4).

If a container of hazardous waste is kept at a "180- or 90-day storage area" for the purpose of collecting small quantities of waste over time, the time limit for that container begins with the original addition of waste. If a filled container of hazardous waste from an "initial accumulation area" arrives at a "180- or 90-day storage area," the time limit for that container began when the volume limit of 55 gallons (or 1 quart of acute hazardous waste) was first exceeded at the "initial accumulation area."

A " 180-day storage area" must be located on site at the installation and be managed in accordance with the following requirements from 40 CFR 262.34 (d).

• The quantity of waste accumulated on-site never exceeds 6,000 kilograms.
• A " 180-day storage area" must comply with specific emergency response and preparedness requirements.
• Any quantity stored in tanks must meet the requirements of 40 CFR 265.201.
• Meets the container storage requirements under the “90-day storage area” requirements listed above that are marked with an asterisk.

• The waste being placed in the container must be compatible with the container. (The operator of the "initial accumulation area" can confirm the compatibility of a stored material and a container material by referencing any of a variety of handbooks or manuals on the subject, such as Table 23-3 of the Chemical Engineering Handbook by Perry and Chilton. The MSDS may also be helpful in identifying suitable storage conditions. Under many circumstances, the only commonly handled wastes not compatible with a steel container are highly corrosive wastes, such as waste acids, which must be stored in a plastic or plastic-lined container.)
• Incompatible wastes must not be placed in the same container unless it does not produce a hazard listed in 40 CFR 265.17(b). Similarly, a waste can not be stored in a container that has previously stored a different waste with which it is incompatible.

3. Container Labeling

For an "initial accumulation area" (per 40 CFR 262.34 [c]):

• Containers must be marked with the words "Hazardous Waste" or with other words that identify the contents of the container.

For a "180- or 90-day storage area" (per 40 CFR 262.34 [a] and [d]):

• The storage container must be labeled with the words "Hazardous Waste".
• Containers that accumulate waste while being stored must be clearly marked with the date when the container began accumulating waste and the date must be visible for inspection on each container.
• Containers that arrive from an "initial accumulation area" must be clearly marked with the date when the container became full.

4. On-Site Movement of Containers

As stated in 40 CFR 263.10 (b), "These regulations [for permitted transportation of hazardous waste via air, water, or public highway] do not apply to on-site transportation of hazardous waste by generators or by owners or operators of permitted hazardous waste management facilities." However, it is recommended that standard safety guidelines for the handling of hazardous waste be implemented for on-site transportation activities. Typical standard operating procedures are as follows.

• Prior to transport, the hazardous waste container must be completely closed and sealed. Bungs must be tightened, and lids must be in place with bolt rings tightened.
• Prior to transport, the container must be inspected to ensure that it can be safely transported without risk of spills or leaks. If a container is damaged, corroded, or otherwise structurally inadequate, the waste must be transferred to a new container or placed in an approved overpack drum prior to moving.
• The transfer of a container between an area and a vehicle must be accomplished using appropriate equipment in a way as to minimize the possibility of an accident or spill.
• Other installation-specific documentation may be required at the time of transfer.

Proper hazardous waste containers, labeling, storage and transportation are required under RCRA, 40 CFR 262.34. Additionally, the proper management of containers minimizes the risk of spills and therefore decreases the possibility the facility will need to meet the emergency response requirements under 40 CFR262.34 (a)(4) and 262.34(d)(5)(iv).

See section on "container selection" above.

Consult your local safety and health personnel for specific precautions.

• Containers that are properly selected, labeled, and handled will minimize the risk of releasing hazardous waste that might lead to facility damage, personal injury, or pollution of the environment.

• Personnel may require "re-training" to learn to modify their regular work habits.

The savings obtained through the use of proper handling techniques of containers of hazardous waste depends on the size of the facility and the activities conducted at the facility. Improper handling can lead to spills and injuries which may be costly for a facility. In addition, most of the requirements in this fact sheet are required to be followed under federal regulations and can carry high civil and criminal penalties if they are not followed.

Approval is controlled locally and should be implemented only after engineering approval has been granted. Major claimant approval is not required.