All containers must be labeled with label marking pens, e.g., the Sharpie extra-fine point marking pen.
Do not use ballpoint pens. Labels and markings must be replaced if they become damaged or lost. Store
containers to allow easy access to container labels. The type of label corresponds with the type of waste.
Labels are not placed over labels. All drums and drum-like containers are labeled as to their contents.
Empty drums and drum-like containers are labeled "empty."
A container or an inner liner removed from a container that has held any hazardous waste is empty if all
wastes have been removed using the practices commonly employed to remove materials from that type of
container by pouring, pumping, aspirating, or scraping. A container that held a hazardous waste of
compressed gas is empty when the pressure in the container is at atmospheric pressure. A container or
inner liner removed from a container that held an acutely hazardous waste is empty if: it is triple rinsed using
a solvent capable of removing the commercial chemical product or manufacturing chemical intermediate,
and is then cleaned by another method that has been shown in the scientific literature, or by tests conducted
by the generator, to achieve equivalent removal; or if the inner liner that prevented contact of the
commercial chemical product or manufacturing chemical intermediate with the container is removed.
Inspection. Facilities provided to store, handle, or use hazardous substances will be periodically tested and
inspected. Some HM/HW considerations for inspection include:
Are amounts of HM on hand limited to the minimum needed (no stockpiling of HM)?
Is the unit's HM/HW inventory (quantity and location) up to date?
Do HW containers have drum logs to account for all additions and to specify personnel authorized to
make additions to the containers?
Are MSDSs on hand for all HM? Are MSDSs readily available to all workers with exposure to HM?
Is HW accumulated in authorized containers?
Are containers labeled according to directives?
Are containers in good condition and closed when not in use?
Are contents of containers compatible with the container?
Are accumulation start dates and HW labels on each HW container?
Are container storage areas inspected at required intervals?
Is HM/HW managed for prompt pick up and transportation to disposal facility according to directives?
Are used oil accumulation tanks used for collection of HW and other pollutants?
Are danger and warning signs conspicuously placed?
Is spill-prevention and -control equipment adequate?
Are personnel trained in the proper handling, collection, storage, or transportation of HM/HW?
Are dumpsters free of HM/HW items?
Are used POL cans and drums disposed of properly?
Are asbestos-containing parts (brake shoes, clutch plates, and equipment insulation) removed, collected,
and disposed of properly?
Are batteries stored/disposed of properly?
Is equipment containing radioactive sources (i.e., gun/mortar sights, M8A1 alarms) properly stored to
prevent breakage and release of radioactive materials? Are incidents reported properly?
Is ammunition stored properly?
Verification of the Proper Conservation of Resources. AR 200-1 addresses the Army hazardous
materials management program. This program outlines the procedures to be implemented by installations and
units to minimize or eliminate the use of hazardous materials when possible, using the following alternatives:
Substitute less hazardous or non-hazardous material.
Modify processes or procedures to reduce or eliminate use.
Restrict user inventory.
Reduce consumptive use.
Direct ordering.
Extend shelf life.
Regenerate spent material.
Downgrade and reuse spent material.
Reuse for other purposes.
Combinations of the above.
Hazardous materials required for testing petroleum products can be some of the most dangerous substances in
use. Most of the hazardous materials used to perform the various tests in the petroleum lab are not
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QM 5183
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