The allowance by the Mass DEP and EPA for working container use under certain conditions in laboratories was intended to give labs more flexibility with waste management and to facilitate compliance. However, compliant working container management can be a challenge. In fact, violations related to the working container rule are included in the DEP’s top 5 list of regulatory violations seen during DEP inspections!
What is a working container? A working container is a small in-use waste container (i.e., 2 gallons or less) that is managed by the staff responsible for the process generating the waste and is used at a bench or workstation. Working containers might include things like flasks and/or beakers used as temporary collection containers in fumes hoods, on benches, or to collect effluent waste from analytical equipment. These small in-use containers are not considered to be satellite accumulation containers and therefore don’t have to be located in posted satellite accumulation areas. Rather, they are regulated as working containers provided certain conditions are met including that the working container must be:
- Located at or near the point of generation
- Under the control of staff directly responsible for the waste collected in the working container
- Managed in a way to prevent spills/releases and located on an impervious surface
- Closed except during active use (i.e., during those parts of the work shift when they are being filled)
- Emptied at the end of the work shift (or when full, whichever comes first) into a satellite accumulation area container that is located at or near the point of generation
- Labeled as hazardous waste and with words describing the nature of, and hazard(s) associated with, the waste.
To promote compliance, it is often helpful to clearly indicate on the waste label that it is a working container that must be emptied daily. Because compliance can be a challenge, some companies have opted not to allow working containers for waste collection and require that all waste be directly emptied into a satellite accumulation container. However, waste effluent from some analytical equipment does not always allow for that and requires the use of a working container. In addition, space may not allow for the collection of waste in a satellite accumulation container (often a 2.5 or 5 gallon carboy) in some fume hoods, so collecting waste in a smaller container such as a beaker is more practical.
For additional information on the working container rule or for tips on complying, please email firstname.lastname@example.org.