United States
              Environmental Protection
              Agency
         OH.ce of
         Solid Waste and
         Emergency Response
         PA
DIRECTIVE NUMBER: 9441.27(84)

TITLE: Regulatory Status of Dibutyltin Difluoride

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APPROVAL DATE: 9-20-84

EFFECTIVE DATE: 9-20-84

ORIGINATING OFFICE: office of solid Waste

E FINAL

D DRAFT

 LEVEL OF DRAFT

   DA — Signed by AA or DAA
   D B — Signed by Office Director
   DC — Review & Comment

REFERENCE (other documents):
  OSWER     OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE   Dl

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PART 261  SUBPART A - GENERAL
                                                DOC:  9441.27(84)
Key Words:    Dibutyltin Difluoride

Regulations:  40 CFR Part 1 Subpart C

Subject:      Regulatory Status of Dibutyltin Difluoride
Addressee:


Originator:

Source Doc:

Date:

Summary:
Don Stanley, Chemical Waste Management, Inc., Route 1, Box 7,
Hanesville, West Virginia  26362

Alan S. Corson, Chief, Studies and Methods Branch

#9441.27(84)

9-20-84
     Since dibutyltin difluoride is not a listed RCRA waste, and the data show
that the waste does not exhibit a Subpart C characteristic, a waste contami-
nated with dibutyltin difluoride would not be a hazardous waste on the basis of
dibutyltin diflouride.  An authorized State may however regulate that waste on
the basis of its toxicity.

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                                                            9441.27 (84)
                               201964
Mr. Don Stanley
Chemical Waste Management,  Inc.
Route 1, Box 7          .'•'"."
Harrisville, .VW 26362

Dear Mr. Stanley:  • -

     This will confirm  our  telephone conversation of August  20,.
1984, regarding the RCRA regulatory status of dibutyltin difluoride
You wanted to know a.bout protective clothing contaminated with
the raw product and baghouse dust collecting unused product.
                         •• -   v  '  .  " . .    '   '      ••"     •••' -•  • .
     Dibutyltin difluoride  is not a listed RCRA waste.  It'Is
the generator's responsibility to test or apply knowledge of
the material in order to determine whether, as a waste, it
exhibits any of the 40  CFR  Part 261 Subpart C characteristics.
The Material Data Safety Sheet and the Ohio EPA analysis of
product appear to confirm your decision that a waste contaminated
with dibutyltin difluoride  would not be a hazardous waste on
the basis of the dibutyltin difluoride. '., *
     .          .    "'..'••••'"      •'        ,
     Of course, the 44  States and territories that have instituted
hazardous waste programs that operate in lieu of RCRA may have
a different viewpoint, especially in view of the TLV.  In any
case, you. and your customer should be aware of the regulatory
standards of any states you deal with.  The RCRA/Superfund
Hotline (800/424-9346) can  send you a list of the State hazardous
waste agency addresses and  phone numbers if you need it.

                                Sincerely yours.
                                Alan S. Corson
                                > •* Chief
                           Studios-and Methods Branch

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