Common Violations of §262.16 Hazardous Waste Labeling in Manufacturing

In the world of manufacturing, keeping up with safety regulations is not just a legal obligation—it's a necessity for the safety of your workforce and the environment. One critical area often overlooked is the proper labeling of hazardous waste under §262.16. Here, we dive into the most common violations, why they matter, and how to avoid them.

Incomplete or Incorrect Labels

One of the most frequent violations we see is incomplete or incorrect labeling. According to the Environmental Protection Agency (EPA), every container of hazardous waste must be labeled with the words 'Hazardous Waste', the applicable hazard(s), and the accumulation start date. In my experience, many facilities miss out on the accumulation start date, which is crucial for tracking how long the waste has been stored.

Mislabeling Hazardous Waste

Mislabeling is another common issue. I've walked through countless manufacturing floors where the labels on containers did not accurately reflect the contents. This not only violates §262.16 but also poses significant risks to workers and emergency responders. Proper training and regular audits can help ensure that labels are accurate and up-to-date.

Failure to Update Labels

Another violation that often slips through the cracks is the failure to update labels when the contents of a container change. If hazardous waste is added to a container, the label must be updated to reflect the new accumulation start date. Based on available research, facilities that implement a systematic review process tend to have fewer violations, though individual results may vary.

Improper Container Management

Improper container management can lead to labeling violations as well. Containers must be kept closed except when adding or removing waste, and they must be in good condition. I've seen facilities where containers were left open, leading to spills and mislabeling. Regular inspections and employee training can mitigate these risks.

How to Avoid These Violations

• Conduct Regular Training: Ensure all employees are trained on the importance of proper labeling and the specific requirements of §262.16.
• Implement Audits: Regular audits can catch labeling errors before they become violations. Use our Job Hazard Analysis reporting to track and manage these audits effectively.
• Use Technology: Leverage safety management software like our LOTO Procedure Management to keep track of hazardous waste containers and ensure compliance.
• Stay Updated: Keep abreast of any changes to regulations and update your procedures accordingly.

By understanding these common violations and implementing proactive measures, manufacturing facilities can ensure compliance with §262.16 and maintain a safer working environment. For further guidance, consider consulting resources from the EPA or the Occupational Safety and Health Administration (OSHA).