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The purpose of this document is to describe the procedures that Hunter College personnel use to determine if waste materials are
regulated as hazardous wastes.
The procedure is applicable to any waste from any source. Hazardous waste identification begins with an obvious point:
in order for any material to be a hazardous waste, it must first be a waste. In other words, will it be discarded?
USEPA developed a set of regulations to assist in determining whether a material is a waste.
RCRA uses the term "solid waste"
in place of the common term "waste." Under RCRA, the term "solid waste" means any waste, whether it is a solid, semisolid, or liquid.
Only a small fraction of all RCRA solid wastes actually qualify as hazardous wastes.
IS THE MATERIAL REGULATORY EXCLUDED FROM BEING A HAZARDOUS WASTE?
Congress and USEPA exempted or excluded certain wastes, like household wastes, from the hazardous waste definition and regulations.
Determining whether or not a waste is excluded or exempted from hazardous waste regulation is the second step in the RCRA hazardous
waste identification process. Only after determining that a solid waste is not excluded from hazardous waste regulation should
the analysis proceed to evaluate the actual chemical hazard that a waste poses.
The final steps in the hazardous waste identification process determine whether a waste actually poses a sufficient chemical or
physical hazard to merit regulation. These steps in the hazardous waste identification process involve evaluating the waste in light
of the regulatory definition of hazardous waste.
A hazardous waste listing is a narrative description of a specific type of waste
that USEPA considers dangerous enough to warrant regulation. Hazardous waste listings describe wastes from various industrial processes,
wastes from specific sectors of industry, or wastes in the form of specific chemical formulations.
IS IT A LISTED HAZARDOUS WASTE?
USEPA has studied and listed as hazardous hundreds of specific industrial waste streams.
These wastes are described or listed on four different lists that are found in the regulations at Part 261, Subpart D.
These four lists are:
§ The F list - The F list designates as hazardous particular wastes from certain common industrial or manufacturing processes.
Because the processes producing these wastes can occur in different sectors of industry, the F list wastes are known as wastes from
nonspecific sources.
The F list is codified in the regulations at Section 261.31.
§ The K list - The K list designates as hazardous particular waste streams from certain specific industries.
K list wastes are known as wastes from specific sources. The K list is found at Section 261.32.
§ The P list and the U list - These two lists are similar in that both list as hazardous pure or commercial grade
formulations of certain specific unused chemicals.
Both the P list and U list are codified in Section 261.33. These four lists each
designate anywhere from 30 to a few hundred waste streams as hazardous.
Each waste on the lists is assigned a waste code consisting
of the letter associated with the list followed by three numbers.
For example, the wastes on the F list are assigned the waste codes
F001, F002, and so on. All wastes listed solely for exhibiting the characteristic of ignitability, corrosivity and/or reactivity
characteristic (including mixtures, derived-from, and as-generated wastes) are not regulated as hazardous wastes once they no
longer exhibit a characteristic.
DOES IT EXHIBIT HAZARDOUS WASTE CHARACTERISTICS?
A hazardous waste characteristic is a property which, when present in a waste, indicates that the waste poses a sufficient threat
to merit regulation as hazardous. When defining hazardous waste characteristics, USEPA does not study particular waste streams
from specific industries.
Instead, USEPA asks the question, "what properties or qualities can a waste have which cause that waste
to be dangerous?" For example, USEPA found that ignitability, or the tendency for a waste to easily catch fire and burn, is a
dangerous property. Thus, ignitability is one of the hazardous waste characteristics and a waste displaying that property is
regulated as hazardous, regardless of whether the waste is listed.
When defining hazardous waste characteristics, USEPA identifies,
where practicable, analytical tests capable of detecting or demonstrating the presence of the characteristic.
For instance,
USEPA regulations reference a laboratory flash point test to be used when deciding if a liquid waste is ignitable. Whether or
not a waste displays a hazardous characteristic generally depends on how it fares in one of the characteristics tests.
Therefore, the chemical makeup or other factors about the composition of a particular waste typically determine whether
or not it tests as hazardous for a characteristic. Using characteristics to define hazardous wastes presents certain
advantages over designating hazardous wastes by listings. One advantage is that hazardous characteristics and the
tests used to evaluate their presence have broad applicability.
Once USEPA has defined a characteristic and selected
a test for use in identifying it, waste handlers can evaluate any waste stream to see if it is classified as a
hazardous waste.
CHARACTERIZATION PROCESS
1) The generator (examples: a graduate student in a laboratory or in an art studio; a facilities staff member)
may make a determination that a waste is hazardous when:
A. The EHSO has previously determined it to be hazardous; or
B. Based on the label information, the waste clearly meets the criteria for a hazardous waste as defined in RCRA and
described in the Hunter College Hazardous Waste Management Plan. It is still worthwhile to confirm this assessment with the EHSO.
2) Any waste chemical or waste solution that is not specifically identifiable by the information on its label
should be referred to the EHSO for characterization.
3) The EHSO may make a determination that a waste is hazardous when:
A. The EHSO has previously determined it to be hazardous;
B. Based on the label information, the waste clearly meets the criteria for a hazardous waste as defined in RCRA
and described in the Hunter College Hazardous Waste Management Plan;
C. The EHSO may send a sample of an unknown waste to a laboratory to evaluate whether it has the characteristics of a
hazardous waste; or
D. Based on the amount of the unknown waste, which may be insufficient to justify the cost of analysis, the EHSO may
decide to dispose of the waste as a hazardous waste without characterization.
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