The document summarizes a presentation given at a Missouri Hazardous Waste Seminar regarding proposed changes to Missouri's packaging, marking, and labeling rules for hazardous waste. It discusses how the current rules differ between Missouri and federal regulations. It outlines two proposed options for new state rules that aim to address concerns of first responders while making rules less strict. It notes how the changes would impact large retailers and that generators would likely continue DOT labeling practices.

1. Lisa Martin, Heritage
Environmental
Services
Kevin Perry, REGFORM
What to Expect in the 2014
Proposed Missouri Packaging,
Marking, and Labeling Rule
Missouri Hazardous Waste Seminar
November 5, 2013
Columbia, Missouri

2. It started with a petition.

3. Their pre-transport sorting system
didn’t work in Missouri.

4. Missouri
Requirement :
Package, mark,
and label
containers in
compliance
with DOT regs
the entire time
“waste is
accumulated in
storage onsite”

5. Can we be more like
the Feds?

6. Federal Requirement :
Package, mark, and
label containers in
compliance with DOT
regs only when offered
for transportation

7. The Commission said, “Take it to the Forum.”

8. Debate.
Give and Take.
Head scratching.
Counter-proposal(s).
Huddling.
A SOLUTION…

9. ...that addressed
the concerns
of first
responders.

10. No Stricter
Law allows
stricter label
regs only, and…
…introduces
tanks into
the mix.

11. § 260.373 RSMo
established
milestones.
On December 31,
2015 “inconsistent”
rules are nullified.
-One “giant” rule
-Proposed in 2014

12. Back to the drawing board

13. There was a new level
of interaction with first
responders at the
Forum.
Forum participants
imagined this
scenario.

14. First responders
were concerned
about this
scenario, too.

15. Requirement
accumulation start date
“Hazardous Waste” label
or mark
no change

16. Option A
Do what you’ve
been doing...
DOT label the
entire time
New:
If <1 gallon, label
the locker or rack.

17. Option B
label each
container
correctly identify
hazard
one or more
1 inch letters
black on white or
white on black
1 gallon threshold

18. When you transport,
don’t leave your Missouri labels on the container.
49 CFR 172.401 violation

19. 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.

20. The big box retailers will be able
to implement their nation-wide
tub sorting system in Missouri.

21. Nothing in the draft rule
currently prohibits
mixed use of both
labeling schemes in a
facility or storage area.

22. 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

23. NFPA diamonds may emerge as an option for
generators with hazardous waste tanks.

24. Lesson learned: the
requirement to annually
familiarize first responders
with generators’ facilities
is not happening.

25. Be Prepared
lisa.martin@heritage-enviro.com
kperry@REGFORM.org