United States
Environmental Protection
Agency
EPA530-F-97-029
September 1997
http ://www.epa .gov
Solid Waste and Emergency Response
Identifying Your
Waste
The Starting
Point
tinted on paper that contains at least 20 percent postconsumer fiber.
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his brochure explains the methodology for identifying hazardous waste under the Resource
Conservation and Recovery Act (RCRA). Companies that produce hazardous waste are
responsible for following a number of regulations regarding the generation, storage, treat-
ment, and disposal of hazardous waste. Call the RCRA Hotline with questions or to order
any of a number of publications (see "For More Information").
If your company generates waste as part of a manu-
facturing or industrial process, you might be subject to
hazardous waste regulations. "Hazardous waste" is a
legal term that describes certain toxic, ignitable, corro-
sive, or reactive wastes generated in manufacturing,
industrial, or other processes. The U.S. Environmental
Protection Agency (EPA) has prepared this simple
guide to explain hazardous wastes and help you deter-
mine whether you generate hazardous wastes and are
subject to regulation. Your company is responsible for
making hazardous waste determinations correctly.
The hazardous waste regulations can be found in
Title 40 of the Code of Federal Regulations (CFR) Part
261-299, which is available at many libraries or can be
obtained from the U.S. Government Printing Office. It
is updated daily with individual issues of the Federal
Register.
Step One:
Is Your Waste a Solid Waste?
You must determine if your waste is a "solid waste"
according to EPA. EPA defines "solid waste" as
garbage, refuse, sludge, or other discarded material
(including solids, semi-solids, liquids, and contained
gaseous materials). For guidance on making this
determination, see the section "For More
Information."
Step Two:
Is Your Waste a Hazardous
Waste?
If your waste is a solid waste, you must then determine
if it is a hazardous waste. It is your responsibility as a gen-
erator either to test your waste or use your knowledge of
the waste to make a determination about its properties.
Once you know what is in your waste, you can then deter-
mine if EPA considers it to be hazardous. EPA defines haz-
ardous waste in six different ways.
A. Is the Waste a "Listed" Hazardous Waste?
EPA developed several lists of hazardous wastes (40 CFR
261.30). If your waste appears on any of these lists, it is
hazardous. Wastes on these lists are hazardous regardless of
the concentrations of hazardous constituents in the waste.
The lists identify:
• Nonspecific source wastes (40 CFR 261. 31), which
are material-specific wastes, such as solvent wastes,
electroplating wastes, or metal heat-treating wastes,
commonly produced by a wide variety (non specific
sources) of manufacturing and industrial processes
(designated with "F" waste codes).
Examples: Wastewater treatment sludges from electroplat-
ing operations (F006), process wastes such as distillation
residues, heavy ends, tars, and reactor clean-out wastes
(F024).
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Specific source wastes (40 CFR 261.32), which are
wastes from specifically identified industries such as
wood preserving, petroleum refining, and organic
chemical manufacturing (designated with "K" waste
codes).
Examples: Wastewater treatment sludge from the produc-
tion of chrome yellow and orange pigments (K002), tar
storage tank residues from coal tar refining (K147).
Discarded commercial chemical products (40 CFR
261.33), which are off-specification products, contain-
er residuals, spill residue runoff, or active ingredients
that have spilled or are unused and intended to be dis-
carded (designated with "P" and "U" waste codes). If
the intent is to use the material or recycle it, it is not
considered a hazardous waste.
Examples: Aldicarb (P070), parathion (P089), and
vinyl chloride (U043).
B. is the Waste a "I
Waste? EPA identified four characteristics, or traits, of
hazardous waste: ignitability, corrosivity, reactivity, and
toxicity (designated with "D" waste codes). Your waste is
considered hazardous if it exhibits any of these characteris-
tics (40 CFR 261.20-24). These properties are measurable
by standardized and available testing methods that can be
found in a manual entitled Test Methods for Evaluating
Solid Waste, Physical/Chemical Methods (SW-846). This
document is available by calling 703 821-4690.
Examples: Certain paints, degreasers, and solvents are
ignitable; battery acid is corrosive; certain cyanides or sulfide-
bearing wastes are reactive; and wastes that contain high con-
centrations of heavy metals, such as cadmium, lead, or mer-
cury, may be considered toxic.
C. Is the Waste a fixture? If your waste is a mkture
of nonhazardous solid wastes and listed hazardous wastes, it
is considered hazardous (40 CFR 261.3). A few wastes are
listed only because they are ignitable or reactive. In these
cases, if the resulting mixture no longer is ignitable or reac-
tive, the mixture is not considered a listed waste.
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Examples: Spent solvents (F003), such as methanol or
acetone, are listed hazardous wastes and are ignitable. If
these solvents are mixed with a non-ignitable nonhaz-
ardous waste, the mixture will still be considered haz-
ardous, unless the mixture is not ignitable.
D. Is Ufa® Waste a "OSeBwed-Fram
Waste? Any solid waste generated (derived) from the
management (treatment, storage, or disposal) of a list-
ed hazardous waste, including sludge, spill residue,
ash, emission control dust, or leachate, is considered
hazardous waste (40 CFR 261.3).
Example: Any ash or residue left from the incinera-
tion process at a hazardous waste incinerator is consid-
ered hazardous waste.
E. is the Wast®
Environmental media (ground water, soil, or sediment)
sometimes come in contact with listed hazardous waste.
If these media become contaminated with (and there-
fore contain) hazardous waste, they must be managed as
a hazardous waste (no regulatory citation).
Exclusions
Be sure to note that some wastes are exclud-
ed from the definition of solid waste and
from the hazardous waste regulations. For
example, domestic sewage, irrigation return
flows, and in-situ mining wastes are excluded
from the definition of solid miste. Household
wastes, agricultural wastes used as fertilizers,
and cement kiln dust are examples of wastes
that are excluded from the definition of haz-
ardous waste. These wastes are not subject
to the federal hazardous waste regulations
but may be subject to other federal regula-
tions or state waste programs,
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Example: If a tank leaks listed hazardous waste into
ground water, the ground water must be managed as a haz-
ardous waste because it contains a listed hazardous waste.
F. Ds ftfoe Wast® CtDODftamroiGfiaftedl PeMs?
Manufactured objects, plant or animal matter, and nat-
ural geological material that exceeds 60 mm (2.36 in)
particle size and that is intended for disposal are consid-
ered "debris" (40 CFR 268.2). Debris is not considered a
solid waste, but if a hazardous waste is mixed with
debris, it becomes hazardous waste.
Example: Rags, personal protective equipment, or wood
pallets that are contaminated with a hazardous waste
must be managed as a hazardous waste until they are
decontaminated and no longer contain the listed waste.
Step Three:
'astes?
If your waste is hazardous, you must comply with
EPA's treatment, storage, and disposal requirements. Since
most states have the authority to pass more stringent haz-
ardous waste regulations, you should also check with your
state hazardous waste agency to learn about additional
requirements. If you generate nonhazardous solid waste,
you should consult your state solid waste agency to deter-
mine any requirements that might apply to you as well. If
your waste is not considered a solid waste, you should
contact your state to determine if the waste is regulated by
other statutes, such as the Clean Water Act.
For more information about waste identification or
the hazardous waste regulations, including a list of
state solid and hazardous waste agencies, contact the
RCRA Hotline at 800 424-9346 or TDD 800 553-
7672. In the Washington, DC, area, call 703 412-
9810 or TDD 703 412-3323. You may wish to order
the document Understanding the Hazardous Waste
Rules: A Handbook for Small Businesses — 1996 Update
(EPA530-K-95-001) from the Hotline. EPA's home
page, www.epa.gov/EPAOSWER/hazwastey can provide
additional information as well.
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The Guiding
Principle
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