I have been told that in certain states such as Pennsylvania and California, a drum of hazardous waste could have three separate accumulation dates over its lifetime. A one year on-site state satellite accumulation start date, a federal over 55 gallon satellite date and a central accumulation date. As some states require one year on-site start dates in the satellite accumulation areas.

They are correct in assuming that there are three different dating requirements on containers in certain states. But, two of the drum’s dates are the same. The one year on-site state start date and the excess waste container over the 55 gallons in satellite accumulation date.

That is why the federal government requires the date to be put on the drum containing excess waste over 55 gallons, (not the full drum) with the excess accumulation of hazardous waste with the date the excess amount began accumulating. It would be impossible to put the start date on the full drum in most cases without blowing through your three day satellite to central accumulation storage area times.

In this way there would only be one date on each satellite accumulation area container, one on the full 55 gallon drum for the state and one on the container, when you start accumulating the excess waste for the feds. This seems to make sense as most generators would move the full drum to the central area within three days. Then add the final central accumulation 180 day or 90 day storage area date. This would make it a total of two dates, not three over its lifetime.

Some generators believe you should date full drums in the satellite areas. To be honest the full drum could stay in the satellite accumulation area until the facility is closed. As long as the generator moved all excess waste over the 55 gallons in satellite accumulation areas within three days of the start of its generation to the central accumulation area.

Maybe you’ve heard contractors, consultants and inspectors tell you differently. I can only tell you what the regulation says. Only a couple seminars left this year so, sign up now.

If you have any questions or comments please don’t hesitate to reach out.

Robert J. Keegan

Hazardous Materials Publishing Company

Transportation Skills Programs Inc.

Hazmat.tsp@gmail.com