Washington State: Hazardous & Dangerous Waste
Meeting regulatory guidelines on labeling your hazardous materials and waste can be very tricky. Where you are in the process with your chemicals will ultimately determine how they should be labeled.
Most hazardous chemical handling goes through a similar process:
- When the chemicals are being stored as good material at your site.
- When the material will be “in use” at your site.
- When the chemicals are completely used and are accumulated or stored as hazardous/dangerous waste at your site.
- Final step: when the chemicals are shipped offsite for disposal/treatment.
As reflected in the chart below, in step one or two, Storage and/or Use: the chemicals are subject to OSHA and fire code labeling.
In step three, Waste: the chemicals are subject to EPA or Washington Department of Ecology labeling.
In the fourth step, Waste Shipment: the chemicals are subject to DOT, EPA, and Washington Department of Ecology labeling requirements.
MATERIAL IN STORAGE – Subject to OSHA & Fire Code Labeling
MATERIAL IN USE – Subject to OSHA and Fire Code Labeling
WASTE – Subject to EPA & Your State’s Waste Labeling
WASTE SHIPMENT – Subject to DOT, EPA & Your State’s Waste Labeling
The fourth step can be especially difficult to navigate, because often the DOT hazard classes and the Washington Department of Ecology’s hazardous/dangerous waste categories don’t match.
For example, you might be required to label a hazardous waste as toxic while it is in storage to satisfy the state, but label it as a Class 9 when it is in transportation to satisfy the DOT. Your state won’t recognize the Class 9 label as a hazardous/dangerous waste risk, so it should not be used while the waste is in storage.
It should also be noted that the DOT prohibits any labeling on a container that can cause confusion. So in the example above, you should remove the toxic label from container before it goes into transportation so that it doesn’t cause confusion with the Class 9 label required by the DOT.
For more information the Washington Department of Ecology has an excellent guide sheet on this topic: