How to Determine If Waste Is Hazardous

What is hazardous waste? Simple answer could be that hazardous waste is a waste with a chemical composition or other properties that make it capable of causing illness, death, or some other harm to humans or other living organisms when it’s released into the environment. On the other hand, to ensure the safe handling of such dangerous waste, regulations demand a far more precise definition of the term.

Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries and chemicals used in the everyday life of the consumers. It may come in many forms, including liquids, solids, gases, and sludges. This article will explore the US regulatory requirements for determining whether the waste should be hazardous or not.

Hazardous waste identification is essential to the success of the hazardous waste management plan or program. The regulations require that anyone who produces or generates waste determine if that waste is hazardous. While doing so, there are a couple of questions s in the hazardous waste identification process that needs to be asked:

  • Is the waste a "solid waste"?

  • Is the waste excluded explicitly from the waste management regulations?

  • Is the waste a "listed" hazardous waste?

  • Does the waste exhibit a characteristic of hazardous waste?

The first thing is to determine if the waste meets the definition of ‘’solid waste’’. "Solid waste" means any garbage or refuse, sludge from a wastewater treatment plant, water supply treatment plant, air pollution control facility, and other material discarded from industrial, commercial, mining, agricultural operations, and community activities.

It is important to note that the definition of solid waste is not limited to physically solid wastes. Solid wastes can be liquid, semi-solid, or even contain gaseous material. After it has been determined that the waste is solid waste, the next step comes. Wastes excluded from the Solid Waste Regulation are mentioned under 40 CFR section 261.4(a).

In the second step, waste management regulations should again be consulted by looking for specific exclusions and if the waste at the facility is excluded or not. Environmental Protection Agency (EPA) excludes some solid wastes from the definition of hazardous waste. Material is not regulated as hazardous waste if said material meets an exclusion criterion from the definition of hazardous waste, even if the material technically exhibits a characteristic that would normally meet this definition. Excluded wastes are listed under 40 CFR section 261.4(b).

It’s important to note that solid waste is hazardous if it is specifically listed as a known hazardous waste or meets the characteristics of hazardous waste.

Now we come to the third step. This step should be checked if the waste from the facility is mentioned under-listed hazardous wastes. Listed wastes are wastes from common manufacturing and industrial processes and specific industries generated from discarded commercial products. The good thing with the listed waste is that the waste generator needs only to know the origin of the waste to determine if it is hazardous or not. Whereas with characteristic waste, laboratory analysis may be necessary.

The final fourth step includes analysing whether the waste exhibits any characteristic of hazardous waste. Characteristic wastes exhibit one or more of the following hazardous characteristic properties: the hazardous waste characteristics are chemical properties that make a waste hazardous for human health or the environment. Determining these characteristics is not an easy task, which is why EPA decided that waste generators must be provided with “widely available and uncomplicated test methods” for determining if wastes exhibited hazardous characteristics.

  • ignitability, 

  • corrosivity,

  • reactivity or

  • toxicity.

Ignitable wastes can easily catch fire and sustain or promote combustion. Wastes that exhibit the ignitability characteristic include liquids with flash points below 60 °C, non-liquids that cause fire through specific conditions, ignitable compressed gases and oxidisers. Test methods for ignitability include the following:

Corrosive wastes exhibit very strong acidic or alkaline properties; these wastes can corrode or dissolve flesh, metal, or other materials. Wastes that exhibit the corrosivity characteristic include aqueous wastes with a pH ≤ 2, or a pH ≥ 12.5 or based on the liquids ability to corrode steel. The test method which should be used to determine corrosivity towards steel is Corrosivity Towards Steel (SW-846 Test Method 1110A).

Reactive waste is a waste that can quickly explode or undergo violent reactions. Wastes that exhibit the reactivity characteristic may be unstable under normal conditions, react with water, give off toxic gases, and be capable of detonation or explosion under normal conditions or when heated. 

Finally, toxicity characteristic is determined by the Toxicity Characteristic Leaching Procedure (TCLP)  (SW-846 Test Method 1311). Wastes that exhibit toxicity characteristics are harmful when ingested or absorbed. Suppose a sample of waste, which is tested, contains any of 39 different toxic chemicals above specified threshold levels. In that case, the waste is considered to exhibit the toxicity characteristic and is regarded as hazardous waste.

As seen from the above, the determination process of whether or not the waste meets the definition of hazardous waste is quite complex. Not to mention that the process can become even more complicated, as is the case with mixed waste. A waste that has both a hazardous component and a radioactive component is called a mixed waste and is regulated under the Resource Conservation and Recovery Act (RCRA) and the Atomic Energy Act. Additionally, hazardous waste can be a mixture of different chemicals. In this case, both individual characteristics of the waste components and mixture need to be taken into account during the determination process. Finally, waste generators always need to remember to consult federal regulations and regulatory requirements and local and state legislation. More often than not, state regulatory requirements for waste management tend to be more stringent than federal requirements.

Every company must ensure safe handling of all wastes to develop a waste management plan and determine if any waste at their facilities is considered hazardous waste or not. With this, you will reduce safety and health risks for your employees and the environment.

 

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