Enforcement in New England
Container Labeling in Laboratories
This statement has been developed to provide Pfizer Inc with Regional EPA guidance to facilitate future compliance at the Groton, Connecticut facility.
RCSA § 22a-449(c)-102(a)(2)(E) requires that wastes stored in satellite accumulation areas be labeled with the words "hazardous waste and with other words that identify the contents of the containers, such as the chemical name."
The Region understands that Pfizer expressed concern to the CT DEP about practical problems relating to labeling satellite accumulation containers in laboratories where small amounts of many different wastes are generated. Subsequently, in consultation with CT DEP inspectors, Pfizer developed a generic label for hazardous waste solvents generated in laboratories. This label reads: "Hazardous Waste Solvents," "Caution: Flammable" and lists the solvents that are potentially stored in the container. CT DEP has reaffirmed that these labels are appropriate for use in laboratories at the Pfizer facility.
Pfizer must ensure that manifests and Land Disposal Restriction notification forms accompanying any shipments of mixed waste streams accurately document all of the solvents listed on the generic label.