Q. Are small containers connected to lab equipment by tubing that fill with hazardous waste in process and that are disconnected and emptied into a 55-gallon satellite accumulation drum when full considered satellite accumulation containers?
A. Yes, your small containers disconnected from laboratory equipment and emptied into a 55-gallon satellite accumulation container are considered satellite accumulation containers. Both the aggregate volume of hazardous waste collected through the container’s connection to the lab equipment and the larger common 55-gallon container must meet all of the requirements for the accumulation of hazardous waste under the generator satellite accumulation rule. The requirements would include those in connection with container condition, labeling requirements, and removing the waste from the satellite accumulation area within a specified period of time.
Bear in mind that when your state adopts the satellite accumulation provisions of the Hazardous Waste Generator Improvements Rule (which goes into effect on the federal level on May 30, 2017) that there will be several new requirements with which you will have to comply.