Hazardous Waste Pre-transport Requirements [40 CFR 262 Subpart C]
40 CFR 262 Subpart C is titled ?Pre-Transport Requirements,? and includes requirements for packaging, labeling, marking, placarding, and accumulation time (262.30, 31, .32, .33, and .34, respectively.) Grouping them like this has caused confusion for many people
Section 34, accumulation time, contains requirements for on-site accumulation: time limits, storage devices, etc. These rules must be followed during the entire accumulation time.
Sections 30 through 33 address the preparation of hazardous waste for shipping to meet DOT requirements. They do not, as many people have asked, apply to the entire time before transporting a hazardous waste off-site. This means that hazardous waste generators do not have to use DOT approved packagings, label them with DOT labels, and placard their wastes until they are prepared for shipment.
Some states (Missouri, for example) do require some DOT information to be marked on containers during accumulation, and their regulations specify these requirements as part of the accumulation rules. Also, use of containers that meet DOT standards is one of the federal EPA?s options for compliance with the Subpart CC volatile organic chemical emission control regulations at 40 CFR 265.1087 (c). However, many generators choose to accumulate their waste in DOT-approved packaging so that the waste does not have to be transferred to another container before shipping.
To learn about these and other hazardous waste management issues, attend our Advanced Hazardous Waste Management Course or Hazardous Waste Management: The Complete Course.
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