3.1  Introduction

3.2  Labeling of Hazardous Chemical Containers

3.3  Container Use

3.4  Flammable Safety Cans

3.5  Satellite Accumulation Area

3.1       Introduction

3.2       Labeling of Hazardous Chemical Containers

The Texas Hazard Communication Act (THCA) requires that all hazardous chemicals be properly labeled. A Hazardous Chemical according to the THCA means an element, compound, or mixture of elements or compounds that is a physical or health hazard, or as a hazardous substance as defined in OSHA 29 CFR 1910, Subpart Z, Toxic or Hazardous Substances, or by the ACGIH, Threshold limits for Chemical Substances. Basically, any compound or chemical that is known to cause a health hazard or physical hazard is a hazardous chemical.

Original (Primary) Container Labels Must Be Maintained (Normally, the original manufacturer’s label in good condition will satisfy this requirement) The supervisors of every University work area where containers of hazardous chemicals are present  are responsible for assuring that the manufacturer or suppliers label is not removed or defaced, unless it is illegible or inaccurate. If re-labeling is required, the label must include, at a minimum, the following items found on the material’s MSDS; name of the chemical, the pertinent physical and health hazards, including the organs that would be affected and the manufacturer’s name and address.

Secondary Containers Must Be Labeled by Department

When a chemical is transferred from its original container into another container for other than immediate use, it is called a secondary container. The supervisors of every University work area are responsible for assuring that all secondary containers are labeled with at least the name of the chemical as it appears on the MSDS and the appropriate hazard warnings.

Limited Exceptions to Labeling Requirement

A container may be unlabeled if it is a portable container intended for the immediate use (same work shift) of the employee who transferred the chemical from a properly labeled container. There are no other exceptions under the THCA.

Reuse of Empty Chemical Containers

Empty chemical containers are considered to be hazardous if they are contaminated with any of the hazardous chemical that they previously contained.  BEFORE putting containers in the trash:

·         Triple rinse container with detergent,

·         Collect the rinsate for appropriate chemical disposal, and  

·         Obliterate the labels.


3.3       Container Use

If you plan to use an empty container to collect hazardous chemical waste for disposal, ensure:

·         The chemical or mixture is compatible with the former contents of the container and the actual container material.

·         All collection vessels must have leak-proof seals with usable closures.

·         Deface the original container label and replace with appropriate content label.

·         If container is used to collect hazardous chemical waste the words “Hazardous Waste” need to be used with the chemical identity.

·         Hazardous chemical waste containers must be kept closed at all times except when in direct use.


3.4       Flammable Safety Cans

In some cases, EPM will provide flammable safety cans for collecting hazardous solvent wastes.   

Note: All waste containers will be maintained closed except when in direct use to reduce volatile vapor exposure and meet state and federal regulation for safe handling of hazardous wastes.


3.5       Satellite Accumulation Area

All the laboratories and other facilities that generate hazardous waste are considered to be satellite accumulation areas. Satellite accumulation area is defined as any area, system or structure being used to store and accumulate hazardous waste temporarily. The hazardous waste generator is responsible for abiding by the following rules: 

·         A satellite accumulation area must be in close proximity of the waste generation location. Removing the waste to another laboratory or across the hall for accumulation is unacceptable.

·         The waste container should always be closed except when waste is actually being poured into container.

·         To protect from spills or leaks from the original container, the use of secondary containment is recommended. 


Hazardous waste containers need to be properly identified. The label should be affixed on the container and be clearly visible with the following items: 

·         List the chemical constituents and composition (include water).

·         Must be labeled with the words “Hazardous Waste“.

·         If the waste is being collected in a “used” bottle or container, ensure the original label is defaced. 

Limits on Time and Quantity            

·         Hazardous waste may be accumulated indefinitely in satellite accumulation up to 55 gallons or 1 quart of acutely toxic hazardous waste. 

·         Once the limits (55 gallons hazardous waste or 1 quart acutely hazardous waste) are met the laboratory staff is required to have the waste removed by EPM within 3 days.  Generally, laboratories do not generate large volumes as described above; it is recommended that once a container (e.g. 4 Liter bottle) is full the generator should schedule a chemical pickup on-line at