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What to Expect in the 2014
Proposed Missouri Packaging,
Marking, and Labeling Rule
Lisa Martin, Heritage
Environmental
Services
Kevin Perry, REGFORM
Missouri Hazardous Waste Seminar
November 5, 2013
Columbia, Missouri
It started with a petition.
Their pre-transport sorting system
didn’t work in Missouri.
Missouri
Requirement :
Package, mark,
and label
containers in
compliance
with DOT regs
the entire time
“waste is
accumulated in
storage on-
site”
Can we be more like
the Feds?
Federal Requirement :
Package, mark, and
label containers in
compliance with DOT
regs only when offered
for transportation
The Commission said, “Take it to the Forum.”
Debate.
Give and Take.
Head scratching.
Counter-proposal(s).
Huddling.
A SOLUTION…
...that addressed
the concerns
of first
responders.
No Stricter
Law allows
stricter label
regs only, and…
…introduces
tanks into
the mix.
§ 260.373 RSMo
established
milestones.
On December 31,
2015 “inconsistent”
rules are nullified.
-One “giant” rule
-Proposed in 2014
Back to the drawing board
There was a new level
of interaction with first
responders at the
Forum.
Forum participants
imagined this
scenario.
First responders
were concerned
about this
scenario, too.
Requirement
accumulation start date
“Hazardous Waste” label
or mark
no change
Option A
Do what you’ve
been doing...
DOT label the
entire time
New:
If <1 gallon, label
the locker or rack.
Option B label each container correctly identify hazard one or more 1 inch letters black on white or white on black 1 gallon threshold
When you transport,
don’t leave your Missouri labels on the container.
49 CFR 172.401 violation
If the rule is adopted, what will change in the
real world?
Very little, especially for SQGs.
Most
generators will
continue to use
DOT labels in
storage.
The big box retailers will be able to implement their nation-wide tub sorting system in Missouri.
Nothing in the draft rule currently prohibits mixed use of both labeling schemes in a facility or storage area.
Tentative tanks provisions
label each tank
correctly identify
any/all hazards
same four words
black on white or white on black
2 sides or ends
letter size
undetermined
NFPA diamonds may emerge as an option for generators with hazardous waste tanks.
Lesson learned: the requirement to annually familiarize first responders with generators’ facilities is not happening.
