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When a facility offers non-RCRA waste material for proper disposal, is the facility required to provide an SDS and HazCom label?

RegSenseWaste GeneratorsWasteOccupational Safety and Health Administration (OSHA), DOLHazard CommunicationEnglishHazcom LabelingSafety Data SheetsSafety & HealthWasteGeneral Industry SafetyBest ResultsFAQHazard CommunicationFocus AreaUSA

When waste does not meet the definition of “hazardous waste” under the Resource Conservation and Recovery Act (RCRA) regulations, it is covered by 1910.1200 if it meets the standard’s definition of “hazardous chemical” at 1910.1200(c) and it does not fall under any of the other HazCom exemptions listed under 1910.1200(b)(6).

For a non-RCRA waste product, OSHA explains that 1910.1200 does not require that the waste generator create its own label or SDS; however, any chemical hazard information, including available labels and SDSs, received by the waste generator from upstream must be passed downstream with the non-RCRA waste product. Source: 10/15/2015 OSHA letter of interpretation.

['Hazard Communication', 'Waste']
['Safety Data Sheets', 'Waste Generators', 'Waste', 'Hazard Communication', 'Hazcom Labeling']
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