Environmental Services 201: A Deeper Dive into Profiling (Second in a 2-Part Series)


The Code of Federal Regulations (40 CFR 262.11) requires generators to determine if their wastes are hazardous. This requirement applies to all generators of hazardous waste including small quantity and large quantity generators. 40 CFR 262.11 of the federal code details the step by step process to determine if wastes are hazardous.

First, the generator determines if the waste is excluded from Resource Conservation and Recovery Act (RCRA) regulations in 40 CFR 261.4. If the waste is not excluded, the generator must determine if the waste is listed in Subpart D of part 261. Third, if the waste is not listed in Subpart D of part 261, the generator must identify any or all relevant characteristics in Subpart D of part 261.

Per Environmental Protection Agency guidelines, generators can either perform analytical testing on, or apply their own “generator knowledge” to, the physical and chemical properties of their wastes. Generator knowledge includes insights into the process and its inputs, reactions and outputs.

Once a generator has determined its waste is subject to RCRA regulations, the generator will often communicate and work with an environmental consultant, environmental service provider or an end disposal facility or Treatment, Storage and Disposal Facility (TSDF) to profile and further categorize the material for acceptance as a hazardous waste.

If analysis was not performed previously by the generator as part of the waste determination process, it may be required by the TSDF prior to profile acceptance. Sampling and analysis guidelines are published by the EPA and are found under Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, or SW846.

Once the material is properly characterized and is found to be a RCRA- or state-regulated waste, the generator and its consultant or environmental services provider will prepare a waste profile for the TSDF.

A typical profile form may include the following information (see attached sample ACTenviro profile):

  • Generator information
  • Physical characteristics of waste
  • Chemical Composition
  • Metals
  • Other components
  • Shipping information
  • Special handling instructions

The waste information is tied to the generator’s site location and EPA ID #, and it will list relevant information regarding the waste and its chemical constituents, hazards and physical and chemical characteristics.

In order to convey the important components of the hazardous waste material to help protect human health and the environment, it is important to accurately describe the waste on the profile form, which will eventually become part of the record of shipments in the generator’s recordkeeping.

– Adam Brandin, Director of Sales