Is My Company’s Waste Hazardous? Reviewing RCRA Toxicity (Part One of a Two-Part Series)

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Under state and federal regulations, businesses must determine if wastes that they generate are “hazardous” based on specific criteria. Federal regulations under the Resource Conservation and Recovery Act (RCRA) created four lists of wastes that are (by definition) considered “hazardous”. F-listed wastes (40 CFR 261.31) come from non-specific processes or activities found at many businesses. K list wastes come from specified industries (40 CFR 261.32). Certain off-spec or discarded commercial chemical products are on the P and U lists (40 CFR 261.33). However, even if a waste is not on one of these lists, generators must still determine if the waste has any hazardous characteristics” including Toxicity, Reactivity, Ignitability and Corrosivity. The definition of “toxicity” under RCRA is surprisingly simple – a waste exhibits characteristic toxicity if it is capable releasing any of 39 substances (defined in 40 CFR 261.24) under simulated landfill conditions. The 39 substances include 8 metals, 6 pesticides and herbicides and 25 other chemicals that do not readily break down in the environment. To simulate landfill conditions, wastes are subjected to the “toxicity characteristic leaching procedure” (TCLP, EPA test method 1311, pronounced “T Clip”). For TCLP analysis, one-part waste solids are extracted with 20 parts acetic acid for 18 hours. After extraction and filtration, the liquid (leachate) is analyzed and if the results exceed regulatory levels (found in 40 CFR 261.24 9(a)) then the waste is considered hazardous due to toxicity and assigned the applicable hazardous waste code. And that’s it! The substances on the RCRA list are all materials that are not likely to break down if released to the environment and therefore need to be managed accordingly. At least under RCRA, the evaluation of hazardous waste toxicity is much simpler than the evaluation of toxicity for workplace safety purposes. If you still have questions, though, we are more than happy to do a free review. However, we are not quite done yet. California goes beyond the RCRA standards. Stay tuned for a review of how California defines hazardous waste toxicity next week.... - ACTenviro Consulting, your EH&S compliance experts

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