1.4 Generator Responsibilities


  1. Collect waste in a suitable container that is in good condition.
  2. Containers must be compatible with waste type.
  3. Containers must remain closed except to add or remove waste.
  4. Containers must be labeled with the words “Hazardous Waste” and its contents identified. Use labels provided by EHS to comply with this requirement.​
  5. Contact EHS for waste removal. Filled containers should be removed within 90 days. If more than 55 gallons has accumulated, it must be removed within 3 days.
  6. A representative of each waste generating area must receive training in hazardous waste management.
  7. Do not mix incompatible chemicals.
  8. Waste must be stored at or near the point of generation, in an area controlled by the generator.

Satellite Accumulation Areas (Waste Accumulation Areas)

EPA rules do not allow for a central accumulation area for collection and storage of waste prior to pickup. EPA views accumulation in a centrally located area as operation of a hazardous waste storage facility. Such operation requires the generator to comply with the full weight of EPA regulations for a treatment and disposal facility. Waste must accumulate where it is generated.


EHS identifies a waste coordinator for each waste generation area. The waste coordinator must receive training in hazardous waste management. Training is available through EHS’s Web page. A representative from EHS is also available to present the training program to large groups at your location. 

Container Requirements

Hazardous waste must be collected in a container that is clean, in sound condition and appropriate for the waste type. Collection bottles must not be overfilled and must be capped with a tight fitting screw type cap; bags and boxes must be tightly sealed.

General Specifications

  1. Container and cap/cap liner must be compatible with waste and in sound condition.
  2. Cap must be screw type and fit tightly - corks and stoppers are unacceptable.
  3. Proper headspace - 1.5 inches for flat top containers, 3 inches for tapered.
  4. Outside of container must be clean and uncontaminated.
  5. Container must be properly labeled. Use labels available from EHS.

Container Selection

Acceptable packaging for specific waste types:

  1. Flammable liquids - glass bottles, steel cans, high-density plastic containers.
  2. Concentrated acids and bases - 2.5-liter “acid” bottle.
    NOTE: One gallon glass bottles are generally unacceptable for acids and bases because the high specific gravity of substances and the thinness of one gallon glass containers increases the likelihood of container breakage. Metal containers and caps or cap liners made of cardboard are incompatible with corrosive materials.
  3. Trace contaminated solid wastes (contaminated paper, gloves, etc.) - double bag using polyethylene bags. Bags should be sealed and placed in sturdy cardboard cartons that are sealed with tape.
  4. Aqueous solutions - glass bottles, plastic bottles, plastic cans. Plastic milk jugs or similar containers are unacceptable.
  5. Broken mercury thermometers - broken thermometers without free flowing mercury may be packaged in the same manner as trace contaminated solid waste. Broken thermometers with mercury should be contained in a glass or plastic bottle with a tight cap.

Proper Liquid Waste Segregation Groups

If different chemical wastes are mixed together in a single container for disposal (commingled), then to the extent possible:

  • Similar types of chemicals should be mixed together to make a common segregation group (see below).
  • Only compatible chemicals may be mixed together within segregation groups. Be sure commingled chemicals are compatible! Caution: mixing chemicals that are incompatible may result in splattering, heat generation, container pressurization, fire or explosion. (See Appendix X for guidance).
  • Keep aqueous-based waste separate from organic solvent-based waste.
  • Keep paper, gloves, syringes and other solid items separate from liquids.
  • Avoid mixing heavy metals, especially mercury, with solvents.

Waste should be commingled within the following general groups, beware of incompatibilities:

  1. Halogenated, e.g., chloroform, methylene chloride.
  2. Hydrocarbon, e.g., xylene, ether, hexane, acetone.
  3. Nitrogenous, e.g., triethylamine, diisopropylamine.
  4. Sulfurous, e.g., dimethylsulfoxide, dimethylsulfate.
  5. Corrosive, e.g., sulfuric acid.
  6. Aqueous solutions, e.g., diaminobenzidine, ethidium bromide, heavy metals.
  7. Oils, e.g., motor oil.

Labeling Requirements

EHS supplies self-adhesive labels that must be applied to each container for pickup. You may also print your own labels from the EHS Web site. If waste is commingled, a label must be put on the container as soon as the waste is first added to the container. This will prevent accidental mixing of incompatible chemicals and satisfy EPA rules.

Why Label Waste?

  • Ensure safety.
  • Prevent waste from becoming an unknown.
  • Comply with EPA regulations.
  • Contribute to the efficiency of material handling.
  • EHS will not pick up waste that is not properly labeled.

Types of Labels

EHS supplies two types of labels for hazardous waste. Make sure the proper label for waste type is used. The label must be either filled out in pencil or may be printed by a computer printer if you are printing labels using the templates available on the EHS Web site.

Label #1

Label #1 (small hazardous waste label) is used on waste that is unused, in original containers, having the original manufacturer’s label. It is also used for waste that has been assigned a code by EHS (see Labeling Procedures, item 11 below). Labels must be filled out in pencil. Be sure the hazardous waste label does not cover the original label. If a container is too small to allow this, the label should be placed next to the container for disposal. The label will be applied to an inventory tag attached to each bottle by EHS.

Label #2

Label #2 (large hazardous waste label) is for commingled wastes, wastes in original containers that are missing original labels, or wastes that are no longer in original containers. Labels must be filled out in pencil or may be printed by a computer printer if you are printing labels through the EHS Web site. All components of the waste must be listed on the label and must total 100%.


Label #3

Label #3 (Universal Waste – Batteries) is to be used on batteries or boxes of batteries that are classified as universal waste.

Label #4

Label #4 (Universal Waste – Lamps) is to be used on boxes holding fluorescent lamps and other types of mercury containing waste lamps.

Lable #5

Label #5 (Mercury Containing Equipment) is to be used on containers holding thermometers, thermostats and other types of mercury containing equipment.

Label #6

Label #6 (Used Oil) is to be used on all containers of used or waste oil.

Labeling Procedures

  1. Only labels provided by EHS are acceptable. Labels may be obtained free of charge by calling 335-8501. You may also print your own labels using templates available on the EHS Web site.
  2. Each container must have a label. The label must be attached to the container when it’s initially used for waste. The date should be filled in when the container is full. The exception for this is the Universal Waste labels for which the date must be filled in immediately.
  3. Labels must be filled out in pencil or may be printed by a computer printer if you are printing labels through the EHS Web site. Pencil is superior due to its resistance to solvent and acid splashes.
  4. Labels must contain name, room number, building, department, and date when required.
  5. Wastes that are commingled must list all components in the contents section, including water and all trace materials.
  6. Abbreviations are not acceptable, write out the full name of chemical constituents.
  7. Aqueous waste should have the pH of the solution recorded.
  8. All used oils must also be marked with the words, "used oil."
  9. Commingled waste containers must have all other labels removed, covered or defaced to avoid identity confusion.
  10. If a container holds only the original contents, the hazardous waste label should be placed so that the original label is not covered. If a container is too small to allow this, the label should be placed next to the container for disposal. The label will be applied to an inventory tag attached to each bottle by EHS. 
  11. For labs that are generating large amounts of the same waste on a continuous basis, a waste code may be obtained to save time when completing labels. Call EHS at 335-8501 for more information.