Painting & Coating Industry (PCI) logo Powder coating summit logo
  • Sign In
  • Create Account
  • Sign Out
  • My Account
  • NEWS
  • PRODUCTS
  • MATERIALS
  • TECHNOLOGIES
  • RESOURCES
  • EVENTS
  • DIRECTORIES
  • EMAGAZINE
  • CONTACT
  • SIGN UP!
cart
facebook twitter linkedin youtube
  • NEWS
  • Latest News
  • Market Trends & Reports
  • Price Alerts
  • Subscribe to eNewsletters
  • Global Top 10/ PCI 25
  • Weekly Featured Article
  • COATLE Word Game
  • PRODUCTS
  • Product News
  • Must See Products and Services
  • MATERIALS
  • Additives
  • Resins/Polymers
  • Pigments
  • Equipment
  • Distributors
  • TECHNOLOGIES
  • Adhesives
  • Architectural Coatings
  • FINISHING
  • Industrial Coatings
  • Nanotechnology
  • Powder Coatings
  • Solventborne
  • Special Purpose Coatings
  • Sustainability
  • UV Coatings
  • Waterborne
  • FINISHING
  • Finishing News
  • Finishing Technologies
  • Finishing Equipment
  • Finishing Today
  • RESOURCES
  • Columns
  • Blogs
  • Coatings Supplier Handbook
  • Podcasts and Videos
  • PCI Store
  • Classifieds
  • eBooks
  • Sponsor Insights
  • White Papers
  • COATLE Word Game
  • Columns
  • Ask Joe Powder
  • Did you know?
  • Distribution Dive
  • Focus on Canada
  • Formulating With Mike
  • Innovation Insights
  • Moody's Coatings Conundrums
  • Powder Coating Perspectives
  • Target the Market
  • TiO2 Insider
  • Blogs
  • Editor's Viewpoint
  • Industry Insights
  • Podcasts and Videos
  • COAT-IT! Podcast
  • Videos/PCI TV
  • EVENTS
  • Coatings Trends & Technologies Summit
  • Paint and Coatings Academy
  • Webinars
  • Calendar of Events
  • Lifetime Achievement Award
  • DIRECTORIES
  • Buyer's Guide
  • Equipment Directory
  • Materials Directory
  • EMAGAZINE
  • Current Issue
  • eMagazine Archive
  • China Issue Archive
  • Editorial Advisory Board
  • CONTACT
  • Contact Us
  • Advertise
  • Subscribe to eMagazine
  • Subscribe to eNewsletters
Painting & Coating Industry (PCI) logo Powder coating summit logo
search
cart
facebook twitter linkedin youtube
  • Sign In
  • Create Account
  • Sign Out
  • My Account
Painting & Coating Industry (PCI) logo Powder coating summit logo
  • NEWS
    • Latest News
    • Market Trends & Reports
    • Price Alerts
    • Subscribe to eNewsletters
    • Global Top 10/ PCI 25
    • Weekly Featured Article
    • COATLE Word Game
  • PRODUCTS
    • Product News
    • Must See Products and Services
  • MATERIALS
    • Additives
    • Resins/Polymers
    • Pigments
    • Equipment
    • Distributors
  • TECHNOLOGIES
    • Adhesives
    • Architectural Coatings
    • FINISHING
      • Finishing News
      • Finishing Technologies
      • Finishing Equipment
      • Finishing Today
    • Industrial Coatings
    • Nanotechnology
    • Powder Coatings
    • Solventborne
    • Special Purpose Coatings
    • Sustainability
    • UV Coatings
    • Waterborne
  • RESOURCES
    • Columns
      • Ask Joe Powder
      • Did you know?
      • Distribution Dive
      • Focus on Canada
      • Formulating With Mike
      • Innovation Insights
      • Moody's Coatings Conundrums
      • Powder Coating Perspectives
      • Target the Market
      • TiO2 Insider
    • Blogs
      • Editor's Viewpoint
      • Industry Insights
    • Coatings Supplier Handbook
    • Podcasts and Videos
      • COAT-IT! Podcast
      • Videos/PCI TV
    • PCI Store
    • Classifieds
    • eBooks
    • Sponsor Insights
    • White Papers
    • COATLE Word Game
  • EVENTS
    • Coatings Trends & Technologies Summit
    • Paint and Coatings Academy
    • Webinars
    • Calendar of Events
    • Lifetime Achievement Award
  • DIRECTORIES
    • Buyer's Guide
    • Equipment Directory
    • Materials Directory
  • EMAGAZINE
    • Current Issue
    • eMagazine Archive
    • China Issue Archive
    • Editorial Advisory Board
  • CONTACT
    • Contact Us
    • Advertise
    • Subscribe to eMagazine
    • Subscribe to eNewsletters
  • SIGN UP!
Paint and Coating EquipmentTesting, Monitoring &Tools

The EPA’s Hazardous Waste Generator Improvements Final Rule

Generators Must Indicate the Hazards of Contents, but Have Flexibility

By Del Williams, Technical Writer, Torrance, California
avery
August 12, 2019

To enhance safety and environmental protection, the EPA’s Hazardous Waste Generator Improvements Final Rule, which became effective federally last year, requires identification including the words “Hazardous Waste,” a description of the container’s hazards, and the date the accumulation started on each container.

Previous Resource Conservation and Recovery Act (RCRA) program labeling regulations did not require waste generators to identify the hazards of waste accumulated in containers, tanks, drip pads and containment buildings. This resulted in a failure to communicate risks associated with wastes being accumulated or stored in different locations, which could put workers, waste handlers, emergency responders and visitors at serious risk.

To resolve this issue, the Final Rule stipulates that container and tank labels must now indicate the hazards of such containers’ contents in numerous affected areas. These include areas for waste generator satellite or central accumulation; transfer facilities consolidating hazardous wastes from different generators; and generator container/tank storage areas at treatment, storage and disposal facilities.

Fortunately, the Final Rule allows ample flexibility in how to comply with this new provision.

For drip pad and containment buildings, the generator can keep this information in logs or records near the accumulation unit.

Waste generators can indicate the hazards of the container’s contents using any of several established methods such as DOT hazard communication, OSHA hazard statement or pictogram, NFPA chemical hazard label, or RCRA characteristic.

Examples of how to indicate the hazards include (but are not limited to):

  • The words of the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic);
  • Hazard communication consistent with the DOT requirements at 49 CFR part 172 subpart E (labeling) or subpart F (placarding);
  • A hazard statement or pictogram consistent with the OSHA Hazard Communication Standard at 29 CFR section 1910.1200;
  • A chemical hazard label consistent with the NFPA code 704.

According to the EPA, the Final Rule provides waste generators some economic and environmental benefits. For example, it provides flexibility to very small-quantity generators (VSQGs) that generate 100 kilograms or less of hazardous waste per month to ship their waste to a large-quantity generator (LQG) under the control of the same company.

The Final Rule also addresses episodic generation of hazardous waste. This occurs when a non-routine event, such as a product recall, results in a smaller generator – a VSQG or small-quantity generator (SQG) – generating an atypical amount of hazardous waste in one month, triggering more stringent generator regulations. Under the Final Rule, a generator can maintain its usual generator category during a non-routine event and avoid the increased requirements of a higher generator status.

The RCRA waste codes must be placed on the containers before shipping hazardous waste off site to a RCRA permitted treatment, storage and disposal facility, but do not need to be applied before that time.

An electronic system, such as a bar code system, is acceptable as long as the RCRA waste code(s) are tied to the specific container.

States not authorized for the RCRA program like Alaska and Iowa are currently required to comply. RCRA-authorized states were required to adopt the more stringent portions of this final rule by July 1, 2018. If a state law must be changed for adoption then the deadline was July 1, 2019.

 

Labeling Options for EPA Hazardous Waste Generator Compliance

While indicating the hazards of the container’s contents in various permissible ways, hazardous waste generator labels must also be very durable and remain attached to the container.

So when it comes to printing EPA Hazardous Waste Generator-compliant labels, one of the easiest ways to become compliant is for companies to use their existing printers along with appropriate printing software.

For the many chemical manufacturers, distributors and end users that are already complying with Globally Harmonized System (GHS) labels for OSHA, this means using GHS labels along with software that utilizes new hazardous waste specific templates.

As an example, companies can use UltraDuty GHS Labels, a leading label brand in the industrial and office markets. Unlike typical labels, these GHS labels are industrial-grade labels designed to be chemical resistant, tear resistant, abrasion resistant, and constructed with a marine-grade adhesive that is waterproof and passes a 90-day seawater submersion adhesion test.

Using Avery’s Design & Print Online Software allows employees to create, customize and print their own hazardous waste labels at their desk from pre-designed, EPA-compliant templates. Most employees find such a process intuitive, since it resembles creating an office document from pre-designed templates.

Printed labels with handwritten (Accumulation Start Date, EPA Waste Codes) or marked hazardous properties (flammable, corrosive, toxic, reactive; along with GHS pictograms) are also acceptable with the Final Rule.

One example of this approach are pre-printed write-on Hazardous Waste Accumulation Labels that comply with EPA’s new Hazardous Waste Generator Improvement Rule. The pre-printed labels allow easy selection of the applicable GHS pictograms or hazardous properties along with accumulation start data and content composition. These help to simplify proper labeling and are compatible with ball point pens and permanent markers. The labels are waterproof and resistant to chemicals, abrasion, tearing and UV, and their permanent adhesive passes a 90-day salt-water immersion test. Such labels can work for a variety of hazardous waste generators including VSQG, SQG, LQG as well as sub-part K (Academic Laboratories). 

 

For more info, visit www.Avery.com/GHS.

KEYWORDS: labeling equipment Labels software

Share This Story

Looking for a reprint of this article?
From high-res PDFs to custom plaques, order your copy today!

Del Williams is a technical writer based in Torrance, California. He writes about health, business, technology and educational issues.

Recommended Content

JOIN TODAY
to unlock your recommendations.

Already have an account? Sign In

  • PCI-0724-Global10-Feature-1440.png

    2024 Global Top 10: Top Paint and Coatings Companies

    Who ranks on top? PCI’s annual ranking of the top 10...
    Paint and Coating Market Reports
    By: Courtney Bassett
  • PCI-0724-PCI25-Feature-1440.png

    2024 PCI 25: Top Paint and Coatings Companies

    PCI's annual ranking of the top 25 North American paint...
    Paint and Coating Market Reports
    By: Courtney Bassett
  • pci1022-Kinaltek-Lead-1170.jpg

    A Novel Pigment Production Technology

    Following an extensive R&D program that demonstrated...
    Paint and Coating Pigments
    By: Jawad Haidar and Nitin Soni
You must login or register in order to post a comment.

Report Abusive Comment

Manage My Account
  • eMagazine
  • eNewsletter
  • Online Registration
  • Subscription Customer Service

CTT Registration Now Open

CTT Registration Now Open

The Coatings Minute: Print Returns with PCI’s New Showcase Issue

The Coatings Minute: Print Returns with PCI’s New Showcase Issue

The Coatings Minute: Why Industry News Matters More Than Ever

The Coatings Minute: Why Industry News Matters More Than Ever

The Coatings Minute: Your Inside Look at PCInnovations

The Coatings Minute: Your Inside Look at PCInnovations

More Videos

Sponsored Content

Sponsored Content is a special paid section where industry companies provide high quality, objective, non-commercial content around topics of interest to the PCI audience. All Sponsored Content is supplied by the advertising company and any opinions expressed in this article are those of the author and not necessarily reflect the views of PCI or its parent company, BNP Media. Interested in participating in our Sponsored Content section? Contact your local rep!

close
  • Modern arapartment complex painted in bright colors.
    Sponsored byEPS - Engineered Polymer Solutions

    Architectural Polymers Leading the Way in Coatings Innovation

  • paint sprayer in a workshop
    Sponsored byallnex

    Enabling Performance and Compliance: allnex Introduces a New Line of VOC Exempt Solvent-Borne Resins

Popular Stories

BASF SE Logo

BASF Reportedly Eyes Exit from Coatings

No. 7 BASF Coatings

BASF Comments on Potential Sale of Coatings Business

Ancamine-2858

Ancamine® 2858 – High-performance solution for hot climates



PCI Buyers Guide

Submit a Request for Proposal (RFP) to suppliers of your choice with details on what you need with a click of a button

Start your RFP

Browse our Buyers Guide for manufacturers and distributors of all types of coatings products and much more!

Find Suppliers

Events

September 3, 2025

Coatings Trends & Technologies Summit

The Coatings Trends & Technologies (CTT) Summit is an annual conference for both liquid and powder coatings formulators and manufacturers to discuss innovations in coatings technology. This event combines high-quality technical presentations, a resource-rich exhibit hall, and dedicated networking opportunities to connect scientific minds, foster innovation, and cultivate game-changing new ideas!

January 1, 2030

Webinar Sponsorship Information

For webinar sponsorship information, visit www.bnpevents.com/webinars or email webinars@bnpmedia.com.

View All Submit An Event

Poll

Longest-running laboratory experiment

What is the longest-running laboratory experiment?
View Results Poll Archive

Products

CTT Summit Short Courses (Live 9/3/25)

Coatings Trends & Technologies Summit is expanding its offerings with four short courses. These short courses will offer an extensive day of interactive learning.

See More Products
pci  webinar april 2025

PCI CASE EBOOK

Related Articles

  • Easing the Transition to GHS Label Compliance

    Easing the Transition to GHS Label Compliance

    See More
  • pci0320-Sabo-115813748-900.jpg

    Achieving Water Authority Compliance with Automated Wastewater Treatment

    See More
  • Kett mixer

    Choosing the Right Lab Mixer for Your Coating

    See More

Related Products

See More Products
  • cold-spray-tech

    Cold Spray Technology

  • organic coatings.jpg

    Organic Coatings: Science and Technology, 4th Edition

  • auto-paints-and-coatings

    Automotive Paints and Coatings, 2nd Edition

See More Products
×

Keep the info flowing with our eNewsletters!

Get the latest industry updates tailored your way.

JOIN TODAY!
  • RESOURCES
    • Advertise
    • Contact Us
    • Directories
    • Store
    • Want More
  • SIGN UP TODAY
    • Create Account
    • eMagazine
    • eNewsletters
    • Customer Service
    • Manage Preferences
  • SERVICES
    • Marketing Services
    • Reprints
    • Market Research
    • List Rental
    • Survey & Sample
  • STAY CONNECTED
    • LinkedIn
    • Facebook
    • Youtube
    • X (Twitter)
  • PRIVACY
    • PRIVACY POLICY
    • TERMS & CONDITIONS
    • DO NOT SELL MY PERSONAL INFORMATION
    • PRIVACY REQUEST
    • ACCESSIBILITY

Copyright ©2025. All Rights Reserved BNP Media.

Design, CMS, Hosting & Web Development :: ePublishing

Painting & Coating Industry (PCI) logo Powder coating summit logo
search
cart
facebook twitter linkedin youtube
  • Sign In
  • Create Account
  • Sign Out
  • My Account
Painting & Coating Industry (PCI) logo Powder coating summit logo
  • NEWS
    • Latest News
    • Market Trends & Reports
    • Price Alerts
    • Subscribe to eNewsletters
    • Global Top 10/ PCI 25
    • Weekly Featured Article
    • COATLE Word Game
  • PRODUCTS
    • Product News
    • Must See Products and Services
  • MATERIALS
    • Additives
    • Resins/Polymers
    • Pigments
    • Equipment
    • Distributors
  • TECHNOLOGIES
    • Adhesives
    • Architectural Coatings
    • FINISHING
      • Finishing News
      • Finishing Technologies
      • Finishing Equipment
      • Finishing Today
    • Industrial Coatings
    • Nanotechnology
    • Powder Coatings
    • Solventborne
    • Special Purpose Coatings
    • Sustainability
    • UV Coatings
    • Waterborne
  • RESOURCES
    • Columns
      • Ask Joe Powder
      • Did you know?
      • Distribution Dive
      • Focus on Canada
      • Formulating With Mike
      • Innovation Insights
      • Moody's Coatings Conundrums
      • Powder Coating Perspectives
      • Target the Market
      • TiO2 Insider
    • Blogs
      • Editor's Viewpoint
      • Industry Insights
    • Coatings Supplier Handbook
    • Podcasts and Videos
      • COAT-IT! Podcast
      • Videos/PCI TV
    • PCI Store
    • Classifieds
    • eBooks
    • Sponsor Insights
    • White Papers
    • COATLE Word Game
  • EVENTS
    • Coatings Trends & Technologies Summit
    • Paint and Coatings Academy
    • Webinars
    • Calendar of Events
    • Lifetime Achievement Award
  • DIRECTORIES
    • Buyer's Guide
    • Equipment Directory
    • Materials Directory
  • EMAGAZINE
    • Current Issue
    • eMagazine Archive
    • China Issue Archive
    • Editorial Advisory Board
  • CONTACT
    • Contact Us
    • Advertise
    • Subscribe to eMagazine
    • Subscribe to eNewsletters
  • SIGN UP!