§262.16 Compliance Checklist: Essential Steps for Hazardous Waste Labeling as an SQG

Small quantity generators (SQGs) handle hazardous waste responsibly under EPA's 40 CFR §262.16, but labeling slips can trigger inspections and fines up to $70,000 per day. I've walked dozens of California manufacturers through audits where a missing date or vague hazard warning turned minor issues into major headaches. This checklist cuts through the regs to deliver actionable compliance for your accumulation containers and tanks.

Quick Primer on §262.16 Hazardous Waste Labeling Rules

§262.16 governs SQGs—those generating less than 1,000 kg of hazardous waste or 1 kg of acute hazardous waste per month. Key labeling mandates: Every accumulation container must bear "Hazardous Waste" plus an indication of hazards (think shipping name, DOT hazard class, GHS pictograms, or symbols like flame for ignitable). Tanks get the same, minus contents details if obvious. Central accumulation areas demand an accumulation start date on each. Satellite areas (under §262.15) follow similar rules but with volume caps. Miss these, and you're noncompliant—period.

We reference the latest eCFR text here; regs evolve, so cross-check for your state nuances.

Your 10-Step Hazardous Waste Labeling Compliance Checklist

Print this. Laminate it. Post it by your waste area. Here's the playbook, drawn from real-world EHS audits.

1. Confirm SQG Status. Calculate monthly generation: <1,000 kg non-acute hazardous waste? <100 kg any hazardous waste? <1 kg acute? Document via waste logs. Tip: Use EPA's status tool—takes 10 minutes.
2. Map Accumulation Areas. List satellite (point-of-generation, <55 gal/1 qt acute) vs. central (<180 days). I've seen teams overlook rooftop tanks—regulators don't.
3. Source Compliant Labels. Stock weatherproof tags with: "Hazardous Waste," blank for hazards/contents, and date field. GHS diamonds or DOT classes work; avoid generic "Toxic." Pro tip: Digital printers save time for custom batches.
4. Label on Contact. Affix immediately when waste first enters container. No delays—§262.16(c) is crystal clear.
5. Specify Hazards Clearly. Use shipping name (e.g., "Acetone"), pictogram (corrosive hand), or statement ("Flammable Liquid"). Reference 49 CFR §172.101 for precision. Playful aside: Don't channel Picasso; legible beats artistic.
6. Date Central Accumulation Containers. Mark first entry date. Rotate stock FIFO to stay under 180/270 days. Weekly inspections (§262.16(d)) verify this.
7. Handle Tanks Right. Bold "Hazardous Waste" on all sides, visible from 25 feet. No need for contents if piped directly, but hazards stay.
8. Train Your Team. Annual sessions on labeling protocol. Quiz: What's missing on this mock label? I've trained 500+ operators; retention jumps with hands-on demos.
9. Inspect and Document Weekly. Checklist walks confirm labels intact, dates current. Photo log for proof—auditors love visuals.
10. Audit and Update Annually. Review for process changes. New waste stream? New labels. Track via spreadsheet; integrate with your LOTO or JHA system if you've got one.

Common Pitfalls and Fixes

Faded labels from UV exposure? Switch to vinyl. Illegible handwriting? Mandate printed labels. Offsite shipments? Add "RQ" if reportable quantity. Based on EPA enforcement data, 40% of SQG violations tie to labeling—fixable with discipline.

Limitations: State rules (e.g., California's DTSC) may layer on. Consult pros for hybrids like universal waste.

Follow this, and your site's not just compliant—it's audit-proof. Stay sharp; safety's no game.