Frequent Questions

A facility palletizes and shrink wraps expired consumer goods in their original packaging. The expired consumer goods are hazardous waste. Does the facility need to label every container with a hazardous waste label or can it label each pallet with a sing

Pursuant to the RCRA regulations, each container used for on-site hazardous waste accumulation must be labeled or marked clearly with the words “Hazardous Waste” and the date on which accumulation began (§262.34(a)(3)). Therefore, the generator must label each individual container on the pallet. A generator may also label the pallet, if he so chooses but the pallet label does not in and of itself satisfy the requirements of §262.34(a)(3). 

During transportation, the consumer goods are subject to Department of Transportation (DOT) requirements for the transportation of hazardous materials, of which manifested hazardous waste is a subset. For more information about the DOT regulations, we suggest that you contact the Hazardous Materials Information Center at 1-800-467-4922. 

Additional guidance regarding the labeling of hazardous waste containers in preparation for transport is available in the following documents: 

Memo, Williams to Smith; November 17, 1987 (RCRA Online #11303)
Memo, Weddle to Staab; January 10, 1984 (RCRA Online #11031)

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