Identifying Hazardous Waste

The Office of Compliance Fact Sheet Series

Updated March 1998 - Doc. No.: 1200

What Is Hazardous Waste?

Your ability to comply with hazardous waste regulations depends on your understanding of what constitutes a hazardous waste. In order to determine if a waste is hazardous, it must first meet the regulatory definition of "solid waste." The U.S. Environmental Protection Agency (EPA) describes a solid waste as:

Any solid, liquid or contained gaseous material that you no longer use, and is recycled, thrown away or stored until you have enough of it to treat or dispose.

If a waste meets the definition of solid waste and is not otherwise exempt from being a hazardous waste, it is then considered to be a hazardous waste if:

• It is included on one of the four lists of hazardous wastes found in the Federal Resource Conservation and Recovery Act (RCRA) regulations (i.e., listed wastes) or:

• It exhibits one of the four defined hazardous waste characteristics of ignitability, corrosivity, reactivity, or toxicity (i.e., characteristic wastes).

Listed wastes

A waste is a listed waste because it has been shown to be harmful to health and the environment when not managed properly. The regulations list over 400 hazardous wastes (40 CFR Part 261). Even if a waste is not found on any of these four Federal lists, it may still be on a State hazardous waste list. For example, many States list waste petroleum oil as a hazardous waste.

Characteristic wastes

If a waste does not appear on one of the EPA lists discussed above, it may still be considered a hazardous waste if it has one or more of the following characteristics:

• It is easily combustible or flammable. This is called an ignitable waste. Ignitable wastes may include solvents, paint wastes, and gasoline.
• It corrodes metals and other materials or has a high or low pH (very acidic or very alkaline). This is called a corrosive waste. Corrosive wastes may include battery acid, caustic paint strippers, and some alkaline or lime-based floor cleaners.

• It is unstable and explodes or produces toxic fumes, gases, and vapors when mixed with water or under other conditions, such as heat or pressure. This is called a reactive waste.

Examples are certain cyanides or sulfide-bearing wastes.

• It is harmful or fatal when ingested or absorbed, or it leaches toxic chemicals into the soil or groundwater when disposed of in the ground. This is known as toxic waste. Wastes with toxic characteristics may include gasolines, solvents, and possibly antifreeze.

Note: The Toxicity Characteristic Leaching Procedure (TCLP) is a standard test used to determine the toxicity of a solid waste. The test is based on the ability of a waste to leach specific metals and chemicals. If the leachate contains more than the regulatory level for a specific chemical, then the material is considered a hazardous waste. For example, if the leachate contains more than 5.0 mg/liter of lead (Pb), then the waste is a "hazardous waste."

Do I Generate Hazardous Waste at My Facility?

Since you are part of the transportation industry, the answer will probably be "yes." However, it is up to you to determine whether your waste is classified as hazardous based on the regulatory definitions. Some wastes that may be familiar to you and that may be considered hazardous waste depending on the state you are in include:

• Non-empty aerosol cans

• Certain discarded or unused chemicals

• Spent cleaning solvents and materials

• Vehicle maintenance wastes.

An important source of information about the chemicals you use is the Material Safety Data Sheet (MSDS). The MSDS is provided by your chemical supplier and gives general health and safety information about handling these chemicals. These MSDSs will not provide you with all of the answers to your environmental questions, but they can help you identify characteristics of your hazardous waste. To ensure that your MSDSs are current, require your vendors to automatically supply you with an MSDS for new products and to have anyone approving purchases in your business ask for them from the supplier. In addition, your national trade association or its local chapter may be able to help you with MSDSs.

Additional Information

Contacts: General information regarding EPA: http://www.epa.gov

RCRA Hotline at 1-800-424-9346.

Publications:

Understanding the Hazardous Waste Rules: A Handbook for Small Businesses - 1996 Update, EPA530-K-95-001, June 1996