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Apples and oranges labeling.
Does the DOT Class 9 “miscellaneous” hazardous materials label meet the RCRA requirements in 40 CFR Part 262 for a generator to mark or label its containers and tanks with an indication of the hazards of the contents?
No. The use of a DOT Class 9 miscellaneous hazardous materials label is not appropriate to meet these RCRA labeling standards.
Unlike DOT Class 1–8 labels, the DOT Class 9 miscellaneous hazardous materials label does not indicate any specific hazard associated with the waste, as required under RCRA. While the DOT Class 9 label does not meet the RCRA onsite accumulation labeling standards, it may be used when applicable to meet DOT requirements.
[EPA generator improvements rule FAQ]
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
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