Proper Labeling Procedure for Hazardous Waste

The complete labeling of waste bottles and all bottles containing hazardous
chemicals is standard operating procedure in this department.  It is spelled
out clearly in the Chemical Hygiene Plan (1.2.ix) that waste containers will
be labeled clearly... with a description that identifies the chemical(s).
This practice is also required of us by the Environmental Protection Agency
of the Federal government and by Ohio EPA.  The Code of Federal
Regulations (40 CFR 262.34) governing handling of hazardous substances
states:
     [the generator] marks his containers either with the words
     "Hazardous Waste" or with other words that identify the
     contents of the container               40 CFR 262.34(c)(1)(ii) 

     The generator must mark the container holding the excess
     accumulation of hazardous waste with the date the excess
     amount began accumulating               40 CFR 262.34(c)(2)

     The generator must ensure that all employees are thoroughly
     familiar with proper waste handling and emergency procedures,
     relevant to the responsibilities during normal facility operations
     and emergencies.                        40 CFR 262.34(d)(5)(iii)

Furthermore, not all people who come in contact with containers of
chemicals in our facility are professional chemists.  For example, emergency
personnel (firemen, paramedics) and maintenance personnel, work-study
students and other students cannot be expected to be able to interpret
chemical formulae at a glance.  Therefore it is important that the full name
of all ingredients be noted on the label. Abbreviations, ions, symbols are
not acceptable.

This applies equally to stock bottles.  The contents should be identified
clearly on the label by full name.  The name of the preparer and the date
prepared are also very helpful.  Other safety information is included as
necessary to ensure that the end-user (the student) is fully aware of any
hazards associated with that chemical's use.
At a minimum, warnings should include whether the material should be used
in the hood, if it is a suspected carcinogen, a lachrymator, strongly caustic
or corrosive, readily absorbed into the skin or mucus membranes, if it is air
or light sensitive, or reactive in water or air, etc.

Every year we spend thousands of dollars on waste disposal, a significant portion of
which is spent to identify unknown or insufficiently identified waste. If we
can decrease this budgetary allocation, that money can be used for things
more useful to everyone like new equipment or graduate stipends...

We do this to protect ourselves and others from physical harm.  We do this
to remain in compliance with OSHA and EPA laws.  Most importantly, we do
this because it is the right thing to do. 
If you have additional questions or concerns they may directed to 
the Chemical Hygiene Officer, Dr. Paul Challen or to Mr. Jeff Your, 
University Hazardous Materials Officer.



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Revised: July 1, 2002