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 % 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 ------- 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. ------- 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 ------- |