Improperly labeled and open hazardous waste containers can result in overflows, spills, confusion among employees and waste haulers, and potentially illegal disposal of hazardous waste. Ensuring the labels are properly affixed and contain accurate information is one part of an efficient hazardous waste management system.

Choose Compatible Containers

Before storing hazardous waste, ensure containers are clean and compatible with the hazardous waste contents. This means the container is made of, or lined with, a material that will not react to, corrode or decay when filled with the hazardous waste. For example, different size plastic and steel containers, IBC tote, super sack, etc.

Learn more about incompatible wastes | View 40 CFR § 265.172 > | View 40 CFR § 265.177 >

Properly Close, Label & Date Containers

In accumulation areas:

• Keep containers closed, unless you are actively adding or removing waste
• Label each container containing hazardous waste, at minimum, with:
  • ​The words "Hazardous Waste"
  • Accumulation start date
  • Indication of the contents, including:
    • The applicable hazardous waste characteristics (i.e., ignitable, corrosive, reactive, toxic)
    • Hazard communication labeling/placarding consistent with DOT requirements¹
    • Hazard statement/pictogram consistent with OSHA Hazard Communication Standard²
    • A chemical hazard label consistent with the National Fire Protection Association code 704

¹49 C.F.R. part 172 | View >
²At 29 C.F.R. 1910.1200 | View >

Waste determinations are required in order to decide whether a material is a solid waste, hazardous waste, or neither. Waste cannot leave the facility without a proper waste determination. The only way to determine the correct disposal method for the waste is to ensure facility representatives know exactly what hazards the material may pose.

Evaluate All Waste

Wastes are generally thought to be generated as an output from a process, but wastes can be generated at any point (byproduct, spills, leaks) | View Flow Chart >

A person who generates a solid waste must make the determination if it is a hazardous waste. This determination must be made at the point of generation, before any dilution, mixing or other alteration. If the generator cannot determine if the waste is hazardous, they must test the waste according to applicable methods.¹

The amount of waste you generate each month determines your generator status. Generator status must be evaluated and updated monthly. Any changes in status must be reported to ADEQ | Learn More >

Examples of waste include excess material, expired off-spec product, discarded adhesives, metal shavings, overspray, used PPE/wipes/rags contaminated with toxic waste, etc. | View Photos > 

Maintain Supporting Documentation

Wastes determination documentation examples:

• Representative sample analysis results from an accredited ADHS environmental laboratory
• Safety Data Sheets
• Process flow diagram
• Chemical reaction diagram
• Updates when products/processes change
  Note: Updating your waste profile at least every three years is recommended

¹Subpart C of 40 C.F.R. part 261 | View >

Unless an exclusion is claimed, treatment, storage, and/or disposal of hazardous waste is illegal without a Resource Conservation and Recovery Act (RCRA) permit. Treating, storing, and/or disposing of hazardous waste should only occur at Treatment, Storage, and/or Disposal Facilities (TSDFs) that have been approved by ADEQ. If a facility claims an exclusion, they must document exactly how they are complying with requirements.

Treating Hazardous Waste

Waste's chemical and physical properties should not be altered from their initial status at the point of generation. Waste should not be allowed to evaporate, volatilize, or solidify as a means of removing hazardous constituents or liquid from the waste.

Only permitted treatment, storage and disposal facilities (TSDFs) can treat hazardous waste, with the following exceptions for generators:

Large Quantity/Small Quantity 

Generally, large and small quantity generators may recycle their hazardous waste on-site without a permit, provided they comply with the waste accumulation time limits and other waste accumulation regulations.¹ In addition, a generator may treat their hazardous waste on-site in a generator accumulation unit (e.g., tank or container) without a hazardous waste permit to render it either non-hazardous or less hazardous, provided they comply with all of the applicable hazardous waste generator requirements,¹ and provided that the treatment is not thermal treatment. Otherwise, treatment and disposal of the hazardous waste is subject to the hazardous waste Treatment, Storage, and Disposal Facility (TSDF) regulations² and permitting regulations.³

Hazardous waste that is destined for land disposal must meet all applicable treatment standards prior to land disposal | View Treatment Standards Table at 40 CFR §268.40 >

Very Small Quantity

Allowed to treat hazardous waste onsite without a permit if the facility meets one of the conditions in code.⁴ If a very small quantity generator does not meet one of these conditions, it:

1. May choose to operate as a Small Quantity Generator and meet the standards that apply to that generator category⁵ or
2. Must have a permit⁶ or operate under interim status⁷ before treating hazardous waste onsite.⁸

Examples of improper treatment of hazardous waste | View Photos > 

Storing Hazardous Waste

• Secondary containment is not meant for storage, therefore it must be maintained, clean and dry
• Waste must be stored in approved containers at all times | View Container Management Tips >
• Volatile chemicals must be contained to prevent emission into the air
• All containers should be free of residues

Examples of proper and improper storage of hazardous waste | View Photos > 

Disposing of Hazardous Waste

• Have hazardous waste transported to a permitted TSDF
• Use a hazardous waste transporter that is registered with ADEQ and has a valid EPA ID # 
• Generators may ship to in-state TSDFs permitted with ADEQ or out-of-state TSDFs permitted in their respective states.

Handling Hazardous Waste Spills or Leaks

If a spill or leak occurs, the hazardous waste must be cleaned up immediately and reported, if necessary. Spills should also be reported to ADEQ at 602-771-2330. After reporting the spill, contact an environmental management company to clean up the spill, if needed.

¹Specified in 40 C.F.R. §§ 262.15 – 17 | View >
²40 C.F.R. parts 264 and 265 | View >
³40 C.F.R. part 270 | View >
⁴40 C.F.R.  261.5(a)(5)(iii) – (vii) 
⁵81 F.R. 85785 | View >
⁶Under Part 270
⁷Per Parts 265 and 270
⁸40 C.F.R. 261.5(g)(3)(i) & (ii)

Universal waste typically has hazardous characteristics and must be handled with care. Lamps such as fluorescent light tubes contain mercury vapor that releases into the environment if the glass is broken. Many batteries contain acid and toxic metals such as lead. These items can be managed and recycled as universal waste, but cannnot be disposed to a landfill. 

To stay in compliance with universal waste requirements and prepare for inspections:

Store in Closed Containers

• Universal waste lamps must be in a structurally sound container
• Containers must be securely closed to prevent mercury vapor from escaping

Examples of improperly and properly closed universal waste containers | View Photos >

Label Containers

• Universal waste containers must labeled “Universal Waste” followed by a description of the waste (e.g., “Universal Waste- Used Lamps”).
• Mark each container with the earliest date the waste is generated and accumulate for no longer than one year

Examples of improperly and properly labeled universal waste containers | View Photos > 

Educate Employees

• Train employees on proper universal waste handling and emergency procedures 
• Supporting documentation of training must be kept on file for all employees that handle and/or manage universal waste

Following are examples of training documentation and records:

• A roster with the date and signatures of the employees
• Certificates with employee name and date
• Providing actual training materials

Provide Training to Employees

Employees who are untrained or inadequately trained in hazardous waste and universal waste management tend to cause deficiencies around the facility that are noticed during compliance inspections.

Training is required for small quantity generators, large quantity generators, and treatment, storage, and disposable facilities.¹ Training requirements include:

• Should be administered by a person trained in hazardous waste management procedures through a classroom instruction program or online training.
• SQGs must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies.²
• LQG facility personnel must successfully complete training that teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. The training program must be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment and emergency systems.

Following are examples of training documentation and records:

• A roster with the date and signatures of the employees
• Certificates with employee name and date
• Providing actual training materials

Maintain Preparedness and Prevention Equipment

Preparedness and prevention measures ensure that the facility is set up properly for emergency responders to do their jobs in the event of an incident at the facility. To minimize possibility of fire, explosion or release of hazardous waste, facilities must be equipped with and maintain:

• Internal communications or alarm system
• Telephone or walky-talkies capable of summoning emergency assistance from local authorities
• Portable fire extinguishers, spill control equipment and decontamination equipment
• Sprinklers, water spray systems or foam spray systems with adequate volume and pressure 
• Adequate aisle spacing
• “No Smoking” sign

Examples of improper and proper facility preparedness and prevention | View Photos > 

Develop and Maintain Contingency Plan and Emergency Procedures

The contingency plan and emergency procedures requirements ensure that employees are prepared to keep themselves safe in the event of an incident. They also ensure that the emergency coordinators know their duties regarding communication with employees and first responders.

All large quantity generators and treatment, storage, and disposal facilities must maintain a contingency plan designed to minimize hazards to public health or the environment from fires, explosions or any release of hazardous waste. The contingency plan:

• Serves as a guide on how to respond to an emergency within the facility
• Shoud include all details found in regulation | Learn More >
• Must be submitted to all police and fire departments, as well as state and local emergency response teams that may be called upon
• Must be updated when processes change or the Emergency Coordinator is replace (even if only temporary)

Once the contingency plan is updated or amended, the facility must include and submit (to all emergency response teams) a quick reference guide.⁴

Small quantity generators are required to have a basic plan.⁵

¹ADEQ does not endorse specific employee training resources. It is the generator's responsibility to find training resources and properly train employees.
²40 C.F.R. 262.16(b)(9)(iii) | View >
³40 C.F.R. 262.17(a)(7) | View >
⁴Per 40 C.F.R. 262.262 | View >
⁵40 C.F.R. 262.16(b)(9) | View >