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printreg, August, 2002
Universal Waste Container Marking Requirements


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From: Debra Jacobson (djacobson@istc.illinois.edu)
Date: Thu, 22 Aug 2002 08:32:32


The following is a regulatory briefing on Universal Waste labeling.
Debra Jacobson ------------------------------------------------------------------------------------------------------------

What are the marking requirements for universal waste containers?

According to 40 CFR 273.14 and 273.34, large quantity and small quantity handlers of universal waste must label or mark the universal waste to identify the type of universal waste as specified below:

a. Universal waste batteries (i.e., each battery), or a container or tank in which the batteries are contained, must be labeled or marked clearly with any one of the following phrases: "Universal Waste--Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)"

b. A container (or multiple container package unit), tank, transport vehicle or vessel in which recalled universal waste pesticides as described in 40 CFR 273.3(a)(1) are contained must be labeled or marked clearly with:
i. The label that was on or accompanied the product as sold or distributed, and
ii. The words "Universal Waste--Pesticide(s)" or "Waste--Pesticide(s)"

c. A container, tank, or transport vehicle or vessel in which unused pesticide products as described in 40 CFR 273.3(a)(2) are contained must be labeled or marked clearly with:
i. The label that was on the product when purchased, if still legible
ii. If using the labels described in paragraph (c)(1)(i) of this section is not feasible, the appropriate label as required under the Department of Transportation regulation 49 CFR part 172
iii. If using the labels described in paragraphs (c) (1)(i) and (1)(ii) of this section is not feasible, another label prescribed or designated by the pesticide collection program, and
iv. The words "Universal Waste--Pesticide(s)" or "Waste--Pesticide(s)" d. Universal waste thermostats (i.e., each thermostat), or a container or tank in which the thermostats are contained, must be labeled or marked clearly with any one of the following phrases: "Universal Waste--Mercury Thermostat(s)," or "Waste Mercury Thermostat(s)," or "Used Mercury Thermostat(s)" e. Each lamp or a container or package in which such lamps are contained must be labeled or marked clearly with any one of the following phrases: "Universal Waste--Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)"

Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center



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