Packaging and marking requirements

• Packaging can be any container authorized by DOT’s regulations to contain a hazardous material.
• It is the generator’s responsibility to properly mark each package of hazardous waste.

The Environmental Protection Agency’s (EPA’s) 262.30 says to package the waste in accordance with the applicable Department of Transportation (DOT) regulations on packaging under 49 CFR Parts 173, 178, and 179. Packaging must conform to the specifications, quantity, and weight limits specified for the DOT hazard class/division and packing group.

Packaging can be any container authorized by DOT’s regulations to contain a hazardous material. This includes boxes, drums, cylinders, portable tanks, intermediate bulk containers, and cargo tanks.

In addition to the requirements for hazardous materials packaging, all packaging must be in compliance with the general packaging requirements at 173.24. These requirements include acceptable condition for transport, compatibility, mixed contents, closures, venting, filling limits, etc.

Marking requirements

EPA requires materials that are to be shipped offsite to meet DOT’s marking regulations at 49 CFR 172.304. EPA says that before transporting a hazardous waste offsite, a generator must mark each container of 119 gallons or less used in transportation as follows:

• HAZARDOUS WASTE — Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
• Generator’s Name and Address __________.
• Generator’s EPA Identification Number __________.
• Manifest Tracking Number __________.
• EPA Hazardous Waste Numbers(s) __________.

Note: A nationally recognized electronic system may be used, such as bar coding, to identify the EPA Hazardous Waste Numbers(s).

Markings provide important information about the contents of a package and help warn of the hazards posed by that material during transport. Markings provide additional information that is not provided by labels or placards about that hazardous material in the package or vehicle.

It is the generator’s responsibility to properly mark each package of hazardous waste.

This responsibility includes:

• Checking that any relevant markings already displayed are in the correct location and are in accordance with the regulations.
• Removing or obliterating any markings which are not applicable or which may reduce the effectiveness of the required markings.
• Applying any new markings in accordance with the regulations.

DOT’s marking specifications

To withstand the conditions normally encountered during transportation, all markings must be:

• Durable;
• In English;
• Printed on, or affixed to, the surface of a package, or on a label, tag, or sign;
• Displayed on a background of sharply-contrasting color;
• Unobscured by labels or attachments; and
• Located away from any other markings — such as advertising — which could substantially reduce their effectiveness.