Simplify Your Approach to Waste ID
Identifying hazardous waste and assigning waste codes is one of the most complex responsibilities in waste management. Many factors need to be considered when making this determination, including the waste’s properties, the hazards it poses, and even the industry in which it was generated.
The EPA’s Resource Conservation and Recovery Act (RCRA) regulations provide a complex system of lists that personnel must use to identify their hazardous waste. Understanding what kinds of waste are on each of these lists, and knowing which lists’s codes apply in a given situation, makes the waste ID process much less daunting than it seems at first glance.
The EPA’s definition of a hazardous waste has two parts that are important for performing waste ID. The EPA defines hazardous waste as a solid waste that exhibits a hazardous characteristic and/or is specifically listed by the EPA as hazardous. [40 CFR 261.3]
Characteristic Wastes
First, wastes that “exhibit a hazardous characteristic” are hazardous waste. There are four “hazardous characteristics” to consider: ignitibility, corrosivity, reactivity (including explosive unstable materials and water-reactive materials), and toxicity (a list of 40 chemical substances). [40 CFR 261, Subpart C]
Listed Wastes
Other wastes are “specifically listed by the EPA as hazardous.” There are four lists of hazardous waste in the RCRA regulations: wastes from non-specific sources (the F list), wastes from specific sources (the K list), acutely hazardous chemical products (the P list), and toxic/other chemical products (the U list). [40 CFR 261, Subpart D]
Understanding these lists and how, when, and where they apply is critical for performing waste ID. Here is a summary of what hazardous wastes might be found on each list.
Hazardous Waste from Non-specific Sources
The F list at 40 CFR 261.31 includes hazardous wastes from non-specific sources. That means the wastes listed here are not specifically associated with particular industrial sectors. The list includes 28 waste streams in the following categories: five kinds of spent solvents, eight secondary materials from metal finishing, nine types of waste from the manufacture of dioxins and chlorinated organics, two types of oil/water separation sludge, and multi-source leachate (e.g., garbage juice from a landfill).
F-listed hazardous wastes are generally toxic, but they may also be ignitable or exhibit other characteristics.
Hazardous Waste from Specific Sources
The K list at 40 CFR 261.32 includes hazardous wastes from specific sources. That means the wastes listed here are associated with particular industrial sectors. The list includes over 150 wastewater treatment sludges, still bottoms, by-products, and other secondary materials generated from the production of pigments, inks, pesticides, explosives, pharmaceuticals, and other organic and inorganic chemicals; secondary materials from petroleum refining sludge and other by-products of smelting iron, steel, aluminum, lead, and coke; and certain residues used in wood preserving. K-listed hazardous wastes are generally toxic, though they may exhibit reactivity or other characteristics.
Acute and Toxic Hazardous Wastes
The P list at 40 CFR 261.33(e) is for commercial chemical products that are acutely hazardous. Acutely hazardous wastes are those that have acute toxic effects on organisms, meaning they have the potential to cause immediate death upon exposure.
The U list at 40 CFR 261.33(f) is primarily for commercial chemical products with toxic hazards. “Toxic” in this context means wastes that have the potential to cause cancer or other chronic health defects upon exposure. The list also includes a few named chemicals with ignitable, corrosive, or reactive properties.
Understanding the EPA’s various hazardous waste lists is the first step to a practical, streamlined approach to performing waste ID. At the Hazardous/Toxic Waste Management Workshop, you can satisfy the EPA’s annual training requirement for hazardous waste personnel and learn best practices for managing waste from “cradle to grave.” Presented nationwide by expert Lion instructors, this engaging two-day workshop is designed for EHS and hazardous waste personnel of any experience level.
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