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The Risk of Improper HazMat Container Disposal

The Risk of Improper HazMat Container Disposal

When disposing of containers that previously held hazardous materials in industrial or workplace settings, even trace amounts of residue can pose significant health, safety, and regulatory risks. While the container materials—plastic, metal, or glass—may seem recyclable, residual hazardous substances can trigger chemical reactions, fires, contamination, or injuries. Worse yet, improper disposal can result in non-compliance with key workplace regulations such as OSHA’s Hazard Communication Standard, WHMIS in Canada, or the Globally Harmonized System (GHS), leading to legal and financial liability.

Under GHS-aligned regulations like OSHA’s HazCom Standard and WHMIS, hazardous products must be clearly labeled, tracked, and safely disposed of—even once their primary use has ended. This includes their empty or nearly empty containers, which may still qualify as hazardous waste.

The Role of SDS in Safe Container Disposal

Section 13 of the Safety Data Sheet (SDS), titled Disposal Considerations, is essential for anyone handling hazardous waste in the workplace. It outlines how to manage both chemical waste and its containers. According to GHS principles, SDS guidance is considered part of a product’s lifecycle management, and failure to follow it could violate workplace safety regulations.

Depending on the substance and residue remaining, containers may still be classified as hazardous waste, requiring specific disposal methods that align with local, provincial, state, or federal regulations. Employers are responsible for ensuring proper disposal procedures are in place and followed, including:

  • Labeling and storing empty containers correctly before disposal
  • Coordinating with licensed waste disposal contractors
  • Training employees on proper disposal protocols

Examples of Regulated Workplace HazMat Containers

The following container types frequently appear in GHS-regulated environments and must be handled with care:

  • Aerosol cans: Pressurized cans used for lubricants, cleaners, or coatings often retain flammable or toxic vapors after use.
  • Chemical drums or bottles: Even “empty” drums, pails, or bottles may contain enough residue to pose a risk. Without proper decontamination or disposal, they can contribute to fires, chemical reactions, or worker exposure.
  • Paint and solvent containers: Leftover residue can be hazardous to health and the environment. Many industrial paints and solvents are regulated under hazardous waste disposal rules, even in small quantities.

Regulatory Accountability and Liability

In the workplace, improper disposal isn’t just a bad practice—it can lead to citations, fines, and liability under OSHA, WHMIS, and applicable environmental legislation (e.g., RCRA in the U.S. or CEPA in Canada).

Best Practices for Employers

To remain compliant and ensure safety:

  • Always consult SDS Section 13 for disposal information
  • Train employees on proper waste handling and container labeling
  • Maintain up-to-date hazardous waste management policies
  • Coordinate with licensed hazardous waste disposal services
  • Document all disposal practices to demonstrate due diligence

Improper container disposal is a regulatory and safety risk. By aligning disposal practices with GHS, OSHA, and WHMIS requirements, employers protect their workers, the environment, and their organization from avoidable incidents and penalties.

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Elton Woodfine

Elton Woodfine CD (Canadian Decoration) served 22 years as a member of the Canadian Forces. Initially as an Infantry section Commander in the Princess Patricia Canadian Lite Infantry (PPCLI), he served on two peace keeping missions in the former Yugoslavia, and one combat tour in Afghanistan where his unit was awarded the Governor General Unit Citation for actions in combat. He then continued to serve as a member of the Royal Canadian Air Force as a firefighter, where he completed a diploma in Fire Science/ Fire-fighting from Memorial University and Occupational Health and Safety diploma from the University of New Brunswick. Lastly, in his career with the Canadian Forces, he served as a member of the Joint Incident Response Unit (CJIRU) as a Chemical, Biological, Radiological and Nuclear Operator (CBRN Op), part of the Canadian Special Operation Command (CANSOFCOM). Upon his retirement from the Canadian Forces, he took a position as a Life Cycle Management of hazardous materials instructor for the logistical branch of the Department of National Defense and is knowledgeable in NFCC, CEPA 1999, IMHWR, TDGR, ICAO, IATA, IMDG, GHS and OH&S federal regulations.

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