For sites that generate potentially hazardous wastes it is imperative that they make a hazardous waste determination for each and every waste generated. The determination process, also called the hazardous waste identification (HWID) process, is one of the first and perhaps the most important step for properly managing waste materials. To make a proper waste identification a generator must ask four questions:
After answering each of these questions a generator will be prepared to facilitate compliant storage and disposal of any wastes generated.
In order to answer the first question, 40 CFR Part 261.2 defines materials that are solid wastes and those that are not solid wastes. RCRA §1004(27) defines a solid waste as, “any garbage, refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material, resulting from industrial, commercial, mining, and agricultural operations and from community activities.”
Additionally, the EPA provides several tools, including a Definition of Solid Waste (DSW) decision tool that can help walk you through this first step.
There are some types of solid wastes that the EPA excludes from the definition of hazardous waste. These materials, regardless of meeting a listing or exhibiting a characteristic of hazardous waste, cannot be considered a hazardous waste. According to §261.4(b), excluded wastes include:
Many of these exclusions are conditional and often specific to an industry or type of waste. Careful reading of the conditional exclusions is necessary when making these determinations.
The EPA has studied hundreds of different waste streams and listed the wastes accordingly. Listed wastes are described or listed on four different lists that can be found at 40 CFR 261, Subpart D. These four lists are:
There are four characteristics of hazardous waste. These characteristics help us understand what the waste is capable of/how it poses a danger. The four characteristics are ignitability, corrosivity, reactivity, and toxicity. Full definitions of these characteristics can be found here.
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