Waste Determination
Making a hazardous waste determination is a critical requirement under federal and state waste regulations. Regulatory agencies closely examine this process during inspections to ensure compliance. Proper waste determinations help prevent environmental harm and ensure safe disposal practices.
To determine whether a material qualifies as hazardous waste, answer the following three questions:
A material is considered waste when it is no longer usable for its inteded purpose.
Does the waste exhbit any of the following properties? If YES - it is hazardous waste.
- Liquids which have a flash point of less than 140°F (60.5°C)
- Flammable solids
- Flammable compressed gases
- Oxidizers/Peroxides
- pH ≤ 2
- inorganic acids- digestion wastes, acid baths
- organic acids - HPLC liquids
- pH ≥ 12.5
- Bases/Alkalines - base baths
- hydroxides, lysis buffers
- Compounds that are normally unstable
- Compounds that react violently with water
- Generates toxic gases, vapors, or fumes
- Capable of denotation or an explosive reaction, or it is a forbidden explosive as defined in 49 CFR 173.54
- A listed wased based on chemical toxicity
- A solid waste containing the contaminants listed above the maximum concentration listed in the attached table when tested by the Toxicity Characteristic Leaching Procedure (TCLP)
EPA and LADEQ regulations also list approximately 450 commercial or off-specification chemicals, waste streams, or their spill residues which must be handled as hazardous wastes due to their acute or chronic toxicity. Refer an EPA Reference Document.
If the material is classified as a waste and meets either of the last two criteria, it must be managed as hazardous waste. These determinations rely on the chemical composition of the waste and process knowledge from the generator.
A proper hazardous waste determination is essential for accurately completing hazardous waste labels. For guidance, contact Environmental Health & Safety (EHS) for assistance.