• How Often You Need to Inspect Hazardous Waste Containers
  • Karen

    Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 100 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) trainer and hazmat technician. She also serves on the Blair County, Pa., LEPC and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenh@newpig.com.

  • Robsays:
    03/21/2016 at 8:35 pm Reply


    You state….”Hazardous waste containers need to be clearly marked with the words “hazardous waste,” a description of the contents and an accumulation start date. The accumulation start date can be used to confirm that hazardous waste containers are moved offsite within the required 90, 180 or 270 days.” I have been looking at switching waste disposal companies and they both have a different take on “accumulation” start date. I have always understood this to mean the first day waste is added to that waste stream then once that container becomes full then it moves to storage. I fall under SQG but could most likely apply for conditionally exempt. When does the 180 start and how does that apply to storage. The more I listen, the more I start to question what I think I know.

    • Karensays:
      03/22/2016 at 1:18 pm Reply

      Hi Rob,

      Thank you for your comment. RCRA’s rules for hazardous waste generators can be confusing – and even seem to contradict themselves at times.

      As a small quantity generator, your rules for accumulation time without a permit are in 40 CFR 262.34(d). You are correct on the 180 day time limit for storage without a permit (unless your waste will be transported more than 200 miles, then you get some additional time). You are also required to meet the requirements of:

      • 40 CFR 265, Subpart I (except .176 and .178): use and management of containers- make sure the contents are compatible and the container is kept closed when waste is not being added or removed
      • 40 CFR 265.201: this is specific to waste stored in tanks
      • 40 CFR 262.34(a)(2): the container must be marked with an accumulation start date
      • 40 CFR 262.34(a)(3): the container must be marked with the words “hazardous waste”
      • 40 CFR 268: Land disposal restrictions

      There are some states that vary on accumulation start date rules, which can add to confusion. You should check your state’s environmental site for state-specific rules that supersede and can be more stringent than the federal rule.

      Under the federal rule, the accumulation start date is the date when the first drop of waste is added to a container of hazardous waste in a central waste storage area. If you are accumulating wastes in satellite storage areas then moving them to a central waste storage area when the amount of waste exceeds 55 gallons (or one quart of acute hazardous waste), the accumulation start date is the date that the container arrives in the central waste storage area. If you are not utilizing satellite accumulation areas and instead collect wastes from different areas in a centralized waste collection area, the accumulation start date is the date that the waste is first added to a collection container.

      Hope this information helps! Please leave another comment if you have any further questions.


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