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Hazardous Waste Labeling and Marking Quick Tips #322 A critical step in the safe handling of hazardous waste is labeling and marking all containers appropriately. To help ensure uniformity In the labeling and marking of containers used for hazardous waste, both the U.S. Department of Transportation (DOT) and U.S. Environmental Protection Agency (EPA) offer specific regulatory guidance for hazardous waste generators to follow. It is importantto note that these requirements are different from the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard, 29 Code of Federal Regulations (CFR) 1910.1200, which offers labeling guidance for hazardous materials that have not been designated as waste. DOT Bulk vs. Non-Bulk Packaging The DOT hazardous waste labeling and marking requirements are different based on the size of the container. Per 49 CFR 171 .8, packaging means a receptacle and any other components or materials necessary for the receptacle to perform Its containment function. Non-Bulk Packaging Non-bulk packaging is defined as packaging that has : A maximum capacity of 450L (119 gal.) or less as a receptacle for a liquid A maximum net mass of 400kg (882 lbs.) or less and a maximum capacity of 450L (119 gal.) or less as a receptacle for a solid A water capacity of 454kg (1 000 lbs.) or less as a receptacle for ages as defined in 49 CPR 173.115 Bulk Packages Under 49 CFR 171 .8, a bulk package is defined as a packagltl�, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment. Bulk packaging Is also defined as large packaging in which hazardous materials are loaded with an intermediate form of containment, such as one or more articles or inner packagings. Additionally, a bulk package has: • A maximum capacity greater than 450L (119 gal.) as a receptacle for a liquid • A maximum net mess greater than 400kg (882 lbs.) and a maximum capacity greater than 450L (119 gal.) as a receptacle for a solid • A water capacity greater than 454kg (1000 lbs.) as a receptacle for a gas as defined In 49 CFR 173.115 While the DOT guidelines for properly labeling and marking non-bulk and bulk containers are similar, they are not the some. This document outlines the rules for non-bulk packaging. Hazardous Waste Labeling vs. Marking The DOT reference to a label is very specific. Labels are the diamond-shaped labels placed on non-bulk containers and resemble bulk container placards. Everything else on a non-bulk package is a marking. Hazardous Waste Labeling The design and size of labels are based on international standards and are used to identify the hazards within the container. Each diamond (square-on-point) label measures at least 100m (4" x 4") on each side as prescribed in 49 CFR 172.407(c)(1 ). DOT Hazardous Waste Label Examples: