United States Environmental Protection Agency
RCRA Hazardous Waste Identification of
Methamphetamine Production Process
By-products
Report To Congress
Under the USA PATRIOT Improvement and Reauthorization Act
of2005
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£ mm \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
S WASHINGTON, D C. 20460
SEP 2 6 2008
THE ADMINISTRATOR
The Honorable Richard B. Cheney
President of the Senate
Washington, DC 20510
Dear Mr. President:
I am pleased to submit the enclosed report entitled, "RCRA Hazardous Waste
Identification of Methamphetamine Production Process By-products," in accordance with
the requirements of section 742 of the USA PATRIOT Improvement and Reauthorization
Act of 2005,42 U.S.C. §692l(j).
If you have questions or comments regarding this report, please contact
Susan Parker Bodine, Assistant Administrator, Office of Solid Waste and Emergency
Response, at (202) 566-0200, or your staff may contact Amy Hayden in the Office of
Congressional and Intergovernmental Relations at (202) 564-0555.
Sincerely,
Stephen crrohnson
Enclosure
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC, 20460
SEP 2 6 2008
THE ADMINISTRATOR
The Honorable Nancy Pelosi
Speaker of the House of Representatives
Washington, DC 20515
Dear Madam Speaker:
I am pleased to submit the enclosed report entitled, "RCRA Hazardous Waste
Identification of Methamphetamine Production Process By-products," accordance with the
requirements of section 742 of the USA PATRIOT Improvement and Reauthorization Act
of 2005, 42 U.S.C. §692l(j).
If you have questions or comments regarding this report, please contact
Susan Parker Bodine, Assistant Administrator, Office of Solid Waste and Emergency
Response, at (202) 566-0200, or your staff may contact Amy Hayden in the Office of
Congressional and Intergovernmental Relations at (202) 564-0555.
Sincerely,
Stephen
Enclosure
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Contents:
I. Introduction 1
II. What is Methamphetamine? 1
III. How is Methamphetamine Produced? 2
IV. RCRA and Other Concerns During Discovery of Illegal Drug Labs 4
V. How Does RCRA Regulate Hazardous Waste? 5
VI. Which Specific Wastes from the Methamphetamine Production 11
Process Would Be Considered Hazardous Wastes under RCRA?
VII. EPA Coordination with State and Federal Law Enforcement 12
VIII. Appendix A: Flow Chart of Primary Methamphetamine Production Processes 14
IX. Appendix B: Chemical Properties and Hazardous Waste Codes Associated 15
with Chemicals Commonly Found at Clandestine Methamphetamine Laboratory
Sites
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I. Introduction
On March 9, 2006, the President signed into law the USA PATRIOT Improvement and
Reauthorization Act of 2005, Pub. L. No. 109-177, 120 Stat. 192 (2006) (USA PATRIOT Act).
This Act contains a provision, amending section 3001 of the Solid Waste Disposal Act, as
amended by the Resource Conservation and Recovery Act (RCRA) (42 U.S.C. § 6921), that
instructs the Administrator of the Environmental Protection Agency (EPA) to, not later than
every two years, submit a report to the Committee on Energy and Commerce of the House of
Representatives and the Committee on Environment and Public Works of the Senate that
identifies the by-products of the methamphetamine (meth) production process and whether the
Administrator considers any of these by-products to be a hazardous waste under Subtitle C of
RCRA. USA PATRIOT Act, Pub. L. No. 109-177, § 742, 120 Stat. 192, 272 (2006). This report
is required to set forth information collected by the Administrator from law enforcement
agencies, States, and other relevant stakeholders that identifies the by-products of the
methamphetamine (meth) production process. Specifically, the report describes how RCRA
regulates hazardous waste, as well as the wastes that are likely to be found at meth labs.
Appendix B also provides a list of by-products from meth production that would likely meet the
RCRA regulatory definition of hazardous waste.
This report fulfills the requirement of section 742 of the Act, which is codified at
42 U.S.C. §69210).
II. What is Methamphetamine?
Meth is a powerful synthetic stimulant drug that comes in several forms and affects the
central nervous system. When it enters the brain, meth triggers a release of norephinephrine,
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dopamine, and serotonin. It can also act as a dopaminergic (reactive to dopamine, a brain
chemical involved in mood regulation) and an adrenergic reuptake inhibitor (reactive to
epinephrine, also a brain chemical responsible for mood regulation), and in high concentrations
as a monoamine oxidase inhibitor (MAOI ), which inhibits the activity of monoamine oxidase,
preventing the breakdown of the serotonin, norepinephrine and dopamine. Meth is similar to
amphetamine; however, an added methyl group causes this compound to be more lipid soluble
and more easily transported across the blood-brain barrier. It is also more stable against
enzymatic degradation. These characteristics contribute to its potency.
III. How is Methamphetamine Produced?
This section generally describes the basic processes used to produce meth in order to
understand the numerous by-products, wastes, and combinations of by-products and wastes that
may be generated and found at any particular laboratory. While meth is produced in small
quantities for limited legal medical uses, meth is produced most frequently for use as an illicit
recreational drug. That is, most meth is produced by illegal, makeshift, clandestine laboratories
using a variety of raw materials and equipment. Below we describe the basic, most common
processes for illicit meth production, and the most common wastes that may be generated. A
more detailed list of wastes which have been identified at illicit meth labs, can be found in
Appendix B.
A. Primary Processes to Produce Methamphetamine
While there are well over 100 "recipes" for making meth, they can be grouped into two
primary processes used to manufacture or "cook" meth. The two primary processes are the
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Anhydrous Ammonia Method and the Red Phosphorus Method. Each method involves three
basic steps: (1) the extraction of the precursor drug; (2) the reduction of the
ephedrine/pseudoephedrine to meth, usually by hydrogenation of the hydroxyl group on the
ephedrine or pseudoephedrine molecule; and (3) the "salting out" stage, which extracts the meth
in solid form from solution using hydrochloric acid (HC1).
While many laboratories perform all three basic steps, it is not uncommon for the various
stages to be divided between labs. Therefore, meth lab by-products and wastes may include
materials considered by-products or wastes by the operators, as well as any intermediate
production products, unused reagent chemicals and produced meth. It also will include
contaminated equipment being used for meth production.
The production method(s) used in any particular lab cannot be identified with certainty,
and the physical evidence at a lab (e.g., chemical raw materials) may only indicate the most
recent method used. A summary flow chart of the processes involved in meth production is
provided in Appendix A.
B. Less Common Procedures for Methamphetamine Production
Meth may also be produced through a process of reductive amination of phenylacetone
with methylamine, both of which are currently U.S. Drug Enforcement Administration (DEA)
List I chemicals (as are pseudoephedrine and ephedrine). The reaction requires a catalyst
(Adams') that acts as a reducing agent, such as mercury aluminum amalgam or platinum dioxide
catalyst. Other less common methods of meth production use other means of hydrogenation
such as hydrogen gas in the presence of a catalyst.
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IV. RCRA and Other Concerns During Discovery of Illegal Drug Labs
Following the discovery of an illegal meth lab by law enforcement, officers collect
samples of the chemicals used in that lab as evidence for prosecution. After all forensic samples
are gathered, a Hazardous Materials (Hazmat) Team is summoned to clean up the remaining
chemicals and other by-products or wastes. Estimates indicate that for each pound of meth
produced, between five and six pounds of highly toxic waste is generated.1 The by-products or
wastes removed by the Hazmat Teams are generally treated as RCRA hazardous waste without
further analysis, and are sent to a RCRA permitted site for treatment and disposal.
State and Federal officials also have found that during the operation of the meth lab, the
residue from meth production may enter porous building materials such as wallboard, carpets
and furnishings.2 In addition to the potential contamination of the building and its contents, there
may be further contamination from the improper disposal of these by-products or wastes by the
producers of the meth, which is typically poured into the indoor plumbing drains that flow either
into the city sewer or individual sewage treatment systems (e.g., septic systems), or modified to
allow drainage directly onto the soil near the meth lab. The other disposal method typically seen
at functioning meth labs is a burn or burial pit. The primary environmental concern from
drainage of these materials into the soil or from disposal into a burn or burial pit is contamination
of ground water by the chemicals, including volatile organic chemicals used in the production of
meth, as well as vapor intrusion which involves soil vapor gas from ground water plumes
1 Bureau of Justice Assistance (1998); Pennell et al. (1999); U.S. Office of National Drag Control Policy (1998);
U.S. Drag Enforcement Administration (DEA)(2000) U.S. Office of National Drag Control Policy (2004)
2 At this time, there is little information known on whether other chemical by-products or wastes may be present on
these porous surfaces. However, if meth itself is found on these porous surfaces, then it is likely that at least some
of the other chemicals used in the production process may also be present.
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infiltrating, and accumulating in, nearby buildings (residences and nonresidential sites) at
dangerous levels.3
In most States, the property owner is responsible for decontamination of the property. In
some States, the health department or another agency may evaluate the property for risks from
long-term exposure to residual chemicals, including the potential environmental impacts of
chemical spills into the environment or improper waste disposal.
V. How Does RCRA Regulate Hazardous Waste?
The determination of whether a particular waste is a Subtitle C RCRA hazardous waste is
a multi-step process that depends on a number of factors, including the chemical character and
composition of the waste. The regulations for making the hazardous waste determination are
found in 40 CFR part 261.4
The first step is to determine whether the waste in question is a solid waste as defined
under RCRA. The RCRA regulations require this determination to be made at the point at which
the waste is initially generated. The hazardous waste regulations define solid waste as any
material, not specifically excluded from the definition of solid waste, that is discarded (i.e.,
abandoned, recycled in certain ways, or certain waste-like munitions) ( 40 CFR 261.2.) In the
case of meth production, any chemical substance and equipment confiscated at the site is
3 "Meth Production in Minnesota", http://www.pca.state.mn.us/publications/c-er5-03.pdf
4 It should be noted that State laws may be more stringent than the Federal RCRA hazardous waste regulations.
Most States have been authorized to implement their own State hazardous waste program in lieu of the Federal
program. This report only addresses the Federal laws and regulations; thus, one must look at the specific State laws
in order to have a full picture of any given situation.
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considered "abandoned," and considered a solid waste under the RCRA hazardous waste
regulations.5
The generator of the solid waste must determine if such waste meets the regulatory
definition of hazardous waste (40 CFR 261.3). For illegal meth labs, because the generator has
abandoned the waste, the Hazmat Team or others responsible for site clean up would make this
hazardous waste determination. EPA's hazardous waste regulations define which solid wastes
are hazardous wastes under Subtitle C of RCRA: generally, a solid waste is hazardous if (1) it is
or contains a listed hazardous waste; or (2) it exhibits one or more of the hazardous waste
characteristics. Either testing or acceptable knowledge of the waste may be used to make this
determination (40 CFR 262.1 l(c)).
A. Listed Wastes
EPA has listed hundreds of industrial waste streams and commercial chemical products
that, if discarded, qualify as hazardous waste. These wastes are grouped into four lists as
follows:
• F list — The F list includes wastes from certain common industrial and
manufacturing processes. Because the processes generating these wastes can occur in
different industry sectors, the F listed wastes are known as wastes from nonspecific
sources. The F list is codified at 40 CFR 261.31.
• K list — The K list includes wastes from specific industries. As a result, K listed
wastes are known as wastes from specific sources. The K list is codified at 40 CFR
261.32.
5 If these materials are held in evidence for court proceedings, they would not be regulated as RCRA hazardous
waste until sent to a facility for treatment or disposal. (Letter from Sylvia K. Lowrance to Mr. Phillip C. McGuire,
08/11/1988, RCRA Online number 11636.)
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• P and U lists — These two lists include chemical substances that are manufactured or
formulated for commercial or manufacturing use and which consists of the
commercially pure grade of the chemical, any technical grades of the chemical that
are produced or marketed, and all formulations in which the chemical is the sole
active ingredient.6 Chemicals are included on the P list if they are identified as acute
hazardous wastes based on criteria described in 40 CFR 261.1 l(a)(2). The U list is
generally comprised of chemicals that are toxic based on criteria described in 40 CFR
261.11(a)(3), but also includes chemicals that display other characteristics such as
ignitability or reactivity. Both the P and U lists are codified in 40 CFR §261.33.
Under the RCRA hazardous waste regulations, mixtures of listed wastes and other solid
wastes or residues derived from the treatment, storage or disposal of a listed hazardous waste is
also considered to be a listed hazardous waste. 40 CFR 261.3(a)(2)(iv) and (c)(2)(i).
In addition, some hazardous wastes are listed solely because they exhibit one or more of
the characteristics of ignitability, corrosivity, and/or reactivity, and may not be regulated the
same as other listed hazardous wastes are regulated under RCRA. (See next section for
discussion of characteristic wastes.) Specifically, when a waste meets the listing description for
one of the 29 wastes that are listed solely because they exhibit the characteristic of ignitability,
corrosivity, and/or reactivity, the waste is not regulated as hazardous if it does not exhibit any of
the characteristics at the point of generation (40 CFR 261.3(g)). For example, F003 (certain non-
halogenated solvents, including acetone, which is used in meth production) is listed for the
characteristic of ignitability. If a waste is generated and meets the listing description for F003
6 The P and U listed hazardous wastes also include: (l)the listed commercial chemical product or manufacturing
chemical intermediate that are off-specification; (2) any residue remaining in a container or in an inner liner
removed from a container that has held the commercial chemical product or manufacturing chemical intermediate;
and (3) any residue or contaminated soil, water or other debris resulting from the cleanup of a spill of any of the
listed commercial chemical product or manufacturing chemical intermediates.
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(based on the solvents it contains) but does not exhibit the characteristic of ignitability at the
point of generation, it is not regulated as a hazardous waste.7
B. Characteristic Wastes
Characteristic wastes are those wastes that (1) may cause or significantly contribute to an
increase in mortality or an increase in serious irreversible or incapacitating reversible illness, or
(2) pose a substantial present or potential hazard to human health or the environment when
improperly managed (40 CFR 261.10(a)). Given these criteria, EPA established four hazardous
waste characteristics: (1) Ignitability, (2) Corrosivity, (3) Reactivity, and (4) Toxicity. Wastes
exhibiting a hazardous characteristic are identified as "D" wastes. The characteristics identify
both acute (near-term) and chronic (long-term) hazards and are an essential supplement to the
hazardous waste listings. For example, some wastes may not meet any listing description
because they do not originate from the specific industry or process identified, but the wastes may
still pose a threat to human health and the environment. Therefore, a facility is also required to
determine whether such waste exhibits a hazardous characteristic, even if it does not meet a
listing description. Any RCRA solid waste produced from or otherwise generated by any
industrial or commercial source, including clandestine meth labs, may exhibit hazardous
characteristics. If a listed waste exhibits a hazardous characteristic, the waste may pose an
additional hazard to human health and the environment and may necessitate additional regulatory
precautions, such as waste treatment requirements under the land disposal restrictions (LDR)
program (40 CFR 268). EPA requires that the characteristics of a hazardous waste should be
7 This assumes that the State program has adopted the Hazardous Waste Identification Rule (HWIR) which added
261.3(g). If the State program has not adopted this Rule, then the waste could be regulated as a hazardous waste.
Most states have adopted the Rule.
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determined by using a standardized test method or by applying general knowledge of the waste's
properties (40 CFR 262.1 l(c)).
The specific hazardous waste characteristics are described as follows:
• Ignitability: The ignitability characteristic identifies wastes that can readily catch fire
and sustain combustion. Specifically, the following qualify as ignitable wastes: (1)
liquid wastes, other than solutions containing 24% alcohol by volume with a
flashpoint of less than 60 degrees C (140 degrees F) using specified tests; (2) non-
liquid waste that can spontaneously catch fire or catch fire through friction or
absorption of moisture under normal handling conditions and burns so vigorously and
persistently that it creates a hazard; (3) certain compressed gases; and (4) substances,
such as chlorate, permanganate, inorganic peroxide or nitrate that yield oxygen
readily to stimulate the combustion of organic matter (i.e., oxidizers). Ignitable
wastes carry the hazardous waste code D001. The regulations providing the
definition of the characteristic of ignitability are codified at 40 CFR 261.21.
• Corrosivity: The corrosivity characteristic identifies wastes that are acidic or alkaline
(basic) or can readily corrode or dissolve flesh, metal, or other materials. EPA uses
two criteria to identify corrosive hazardous wastes. Specifically, aqueous wastes are
considered corrosive if they have a pH greater than or equal to 12.5 or less than or
equal to 2. Liquid wastes are considered corrosive if they corrode steel at a rate
greater than 6.35 mm per year using a specific test method. Corrosive wastes carry
the hazardous waste code D002. The regulations providing the definition of the
characteristic of corrosivity are codified at 40 CFR 261.22.
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• Reactivity: The reactivity characteristic identifies wastes that readily explode or
undergo violent reactions or react to produce toxic gases. Specifically, wastes are
considered reactive if they: (1) are normally unstable and readily undergo violent
change without detonation; (2) react violently with water; (3) form potentially
explosive mixtures with water; (4) generate toxic gases, vapors or fumes when mixed
with water; (5) are a cyanide or sulfide bearing material which, when exposed to pH
conditions between 2 and 12.5 can generate toxic gases, vapors, or fumes; (6) are
capable of detonation or explosive reactions if subjected to a strong initiating source
or if heated under confinement; (7) are readily capable of detonation or explosive
decomposition or reaction at standard temperature and pressure; and/or (8) are a
forbidden explosive as defined in Department of Transportation (DOT) regulations.
Unlike many of the other hazardous characteristics that require the use of a specific
test method, the reactivity characteristic is based primarily on narrative descriptions.
Thus, determining whether a waste at a meth lab is reactive is somewhat subjective.
Reactive wastes carry the hazardous waste code D003. The regulations providing the
definition of the reactivity characteristic are codified at 40 CFR 261.23.
• Toxicity: The toxicity characteristic (TC) identifies wastes that are likely to leach
dangerous concentrations of toxic chemicals into ground water. In order to predict
whether any particular waste is likely to leach chemicals into ground water at
dangerous levels, EPA designed a laboratory procedure to estimate the leaching
potential of wastes when disposed of in municipal solid waste landfills. This lab
procedure is known as the Toxicity Characteristic Leaching Procedure (TCLP).
There are 40 different chemicals for which specified regulatory levels have been
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determined, identified as D004 - D043. The regulations providing the definition of
the toxicity characteristic are codified at 40 CFR 261.24 and the TC regulatory levels
appear in Table 1 of that same section.
VI. Which Specific Wastes from the Methamphetamine Production Process Would Be
Considered Hazardous Wastes under RCRA?
As stated above, the determination of whether a particular waste meets the definition of
"hazardous" under the RCRA Subtitle C hazardous waste regulations is determined by more than
simply its chemical makeup. The waste identification process can be complicated, and it is
generally not possible to make a blanket statement as to whether a waste would be defined as
hazardous under RCRA without knowing specific details about its generation. This may be
particularly true for wastes generated at meth labs because there are many variations in the
production methods and materials used. However, it is possible to identify many meth lab
wastes that are likely to meet the definition of hazardous waste under the RCRA hazardous waste
regulations.
Because the methamphetamine production process is not one of the specific industries
whose wastes are identified in the K list, meth lab wastes, if a listed hazardous waste, would be
listed as hazardous either as an F list hazardous waste or a P or U list hazardous waste. For
example, many solvents used in meth production processes may result in some of these wastes
identified as F001 - F005 hazardous wastes. It is also possible that some of the reagent
chemicals used in the meth production process might be listed on the P and U lists of commercial
chemical products and manufacturing chemical intermediates.
It also is likely that many of the wastes that are generated during the meth production
process exhibit one or more of the hazardous characteristics. For example, many meth labs are
11
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identified as a result of an explosion, demonstrating quite clearly the "ignitability" or "reactivity"
characteristic (Hazardous Waste Code D001 or D003). Because the hazardous characteristics
address properties of the wastes, whether meth lab waste will exhibit a hazardous characteristics
will likely vary. For example, a pure solvent may have a low flash point and be classified as
ignitable-DOOl. If mixed with other wastes, the ignitability of the mixture may be different and
the waste may no longer be considered ignitable-DOOl; however, it may still meet the narrative
definition of "reactivity."
The tables in Appendix B, modified from a table contained in the Drug Enforcement
Agency (DBA) "Guidelines for the Cleanup of Clandestine Drug Laboratories," identify
hazardous waste codes that may apply to various wastes found in meth production laboratories.
VII. EPA Coordination with State and Federal Law Enforcement
Responding to the Anti-Drug Abuse Act of 1988 (P.L. 100-690), EPA, DBA, and the U.S.
Coast Guard came together to form a "Joint Federal Task Force" and collaboratively developed
the Guidelines for the Cleanup of Clandestine Drug Laboratories (March 1990). EPA also
contributed to DEA's 2005 update of the 1990 Guidelines for the Cleanup of Clandestine Drug
Laboratories. This document continues to be widely used by local law enforcement when
responding to meth labs.8
In addition, EPA has coordinated extensively with local, State and Federal law
enforcement on strategies for dealing with clandestine meth labs. Specifically:
• In 2000, EPA developed a train-the-trainer course for first responders, State, and
Federal personnel who might come in contact with former meth labs. The course,
8 "Guidelines for the Cleanup of Clandestine Drug Laboratories 2005 Edition," Drug Enforcement Administration.
http: //www.usdoi. go v/dea/resources/redbook.html
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Methamphetamine Awareness and Operations for First Responders, has been
conducted nationwide over the last eight years.
• EPA, in coordination with the States, continues its meth lab hazard control and
prevention work by developing a set of voluntary guidelines for meth lab
remediation. This document will be a broad set of voluntary guidelines that provides
a review of Federal and State meth remediation guidance documents and other
relevant studies and potential best practices. EPA intends to complete this document
by December 2008 to meet the requirements of both the Synthetic Drug Control
Strategy: A Focus on Methamphetamine and Prescription Drug Abuse issued in June
2006 by the White House Office of National Drug Control9, and the
Methamphetamine Remediation Research Act of 2007 that was signed into law on
December 21, 2007 (Public Law No: 110-143).
9 http://www.ondcp.gov/publications/svnthetic drg control strat/svnth strat.pdf
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Appendix A: Flow Chart of Primary Methamphetamine Production Processes
10
Extracting Precursor Drug
Use: cold tablets, solvent (nail polish remover, paint thinner) and coffee filters
Byproducts: Solvent vapors, ephedrine or pseudoephedrine, binder from tablets,
and coffee filters
Solvent evaporates or may be reused.
Red Phosphorus Method
Use: Iodine, red phosphorus, hydroiodic acid
(HI), hydrochloric (muriatic) acid, sulfuric acid,
sodium hydroxide (lye), sodium chloride (salt
isopropyl alcohol, ethyl alcohol (ethanol),
methyl alcohol (methanol), hydrogen peroxide,
naphtha (Coleman fuel), charcoal lighter fluid
(mineral spirits, petroleum distillate), acetone,
benzene, toluene, ethyl ether (starting fluid),
Freon, hydrogen chloride gas, and chloroform.
Other chemicals that may be used include acetic
acid, methyl-ethyl-ketone (MEK) and
hypophosphoric acid.
By-products: Iodine, red, white and yellow
phosphorus, sodium hydroxide, phosphine gas,
hydrogen chloride gas, coffee filters, solvent,
and possible other bv-oroducts.
Anhydrous Ammonia Method
Use: Sodium, potassium, or lithium metal,
anhydrous ammonia, water, ether or other
solvent, [isopropyl alcohol, ethyl alcohol
(ethanol), methyl alcohol (methanol),
hydrogen chloride gas, hydrochloric
(muriatic) acid, sulfuric acid, sodium
chloride (salt), toluene, naphtha (Coleman
fuel) , Freon, ethyl ether (starter fluid),
chloroform, and methyl-ethyl-ketone
(MEK)]
Exothermic reaction can cause gaseous
by-products
Heat may be used to expedite solvent
evaporation.
By-products: coffee filters, excess metal,
hydrogen chloride gas
"Salting out"
Use: Rock salt or table salt, sulfuric or muriatic acid, filters.
Byproducts: Excess salt, sulfuric or muriatic acid, hydrochloric acid,
hydrogen chloride gas, coffee filters, meth, solvent from above phases,
possibly acetone.
' Modified from chart in MN "Meth Production in Minnesota: Cooking Methods.'
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Appendix B: Chemical Properties and Hazardous Waste Codes Associated with Chemicals
Commonly Found at Clandestine Methamphetamine Laboratory Sites.
(Modified from tables contained in the DEA "Guidelines for the Cleanup of Clandestine Drug
Laboratories.")
TABLE B-l: CYANIDES (all in this list potentially meet reactivity characteristic -D003 )
Substance
Sodium Cyanide
Potassium Cyanide
Benzyl Cyanide
Hydrogen Cyanide
Form
Solid
Solid
Liquid
Gas,11 Liquid
Exposure
Skin, Eyes, Ingestion
Skin, Eyes, Ingestion
Skin, Eyes, Inhalation, Ingestion
Inhalation
EPA Hazardous
Waste Code
P106
P098
D003,D018
P063
TABLE B-2: IRRITANTS AND CORROSIVES
Substance
Acetic Acid
Acetic Anhydride
Acetyl Chloride
Ammonium Hydroxide
Benzyl Chloride
Dimethylsulfate
Formaldehyde
Formic Acid
Hydrogen Chloride/Hydrochloric
Acid
Hydrobromic Acid
Form
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Gas, Liquid
Liquid
Gas, Liquid
Liquid
Exposure
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
EPA Hazardous
Waste Code
D00112
D001
U006
D002
P028, DO 18
U103, D003
U122
U123,D00113
D00214
D003
11 Ignitable contained gases intended for discard are regulated under RCRA.
12 Ignitable at high concentrations (e.g. 96%).
14
1 At 55% concentration, but not at 62% concentration.
Only liquids can be classified as D002. Solids and gases cannot be classified as D002, even if they are corrosive.
Refer to 40 CFR 261.33 for a detailed definition.
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TABLE B-2: IRRITANTS AND CORROSIVES
Substance
Hydriodic Acid
Hydroxylamine
Methylamine
Methylene Chloride
(dichloromethane, methylene
dichloride)
Methyl Methacrylate
Nitroethane
Oxalyl Chloride
Perchloric Acid
Phenylmagnesium Bromide
Phosphine
Phosphorous Oxychloride
Phosphorous Pentoxide
Sodium Amide (Sodamide)
Sodium Metal
Sodium Hydroxide
Sulfur Trioxide
Sulfuric Acid
Tetrahydrofuran
Thionyl Chloride
Form
Liquid
Liquid,
Solid
Gas,
Liquid,
Solid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Gas
Solid
Solid
Solid
Solid
Liquid,
Solid
Liquid,
Solid
Liquid
Liquid
Liquid
Exposure
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes
Skin, Eyes, Inhalation
Skin, Eyes
Skin, Eyes
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
EPA Hazardous
Waste Code
D002, D002
D003
D001
U080
U162
D001
D003
D001
D001,D003
P096
D003
D003
D003
D003
D002
D001,D002D003
D002
U213
D003
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TABLE B-3: SOLVENTS
Substance
Acetone
Acetonitrile
Aniline
Benzene
Benzyl Chloride
Carbon Tetrachloride
Chloroform
Cyclohexanone
Dioxane
Ethanol
Ethyl Acetate
Ethyl Ether
Freon 11
(trichloromonofluoromet
hane)
Hexane
Isopropanol
Methanol
Methylene Chloride
(dichloromethane,
methylene dichloride)
Petroleum Ether
Pyridine
Toluene
o-Toluidine
Form
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Exposure
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
EPA Hazardous
Waste Code
U002,D001
U003,D001
U012
U019,D018,D001
P028, D018, D001
U211,D019
U044, D022
U057, D001
U108,D001
D001
Ul 12,0001
Ul 17,0001,0003
U121
0001
0001
U154, D001
U080
D001
U 196,0001
U220,D001
U328, D001
17
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TABLE B-4: METALS/SALTS
Substance
Magnesium metal
Red Phosphorus
Mercuric Chloride
Lead Acetate
Lithium Aluminum
Hydride
Lithium Hydroxide
Potassium Hydroxide15
Raney Nickel
Sodium Hydroxide16
Sodium Metal
Potassium Metal
Form
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid in kerosene
Solid in kerosene
Exposure
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
EPA Hazardous Waste Code
D003
D003
D003, D009
U144, D008
D001, D003
D003
D003
D003
D003
D003
D003
Table B-5: OTHER POTENTIALLY HAZARDOUS PRECURSORS, SOLVENTS, REAGENTS,
DRUG PRODUCTS AND BY-PRODUCTS FOUND IN CLANDESTINE DRUG
LABORATORIES, WHICH WOULD NOT BE CONSIDERED TO BE HAZARDOUS WASTE
UNDER RCRA
Substance
Ammonia (anhydrous)
Aluminum Chloride
Palladium
Iodine
Thorium Salts
Fentanyl
Hydrogen
Lysergic Acid Diethylamide (LSD)
MPTP, MPPP17
Methylfentanyl
Phenylacetic Acid
Phenyl-2-Propane (phenylacetone)
Piperidine
Form
Gas
Solid
Solid
Solid
Solid
Solid
Gas
Powder
Solids
Solid
Solid
Liquid
Liquid
Exposure
Skin, Eyes, Inhalation
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Inhalation, Skin, Eyes
Inhalation
Ingestion, Inhalation
Inhalation, Skin
Inhalation, Skin, Eyes
Skin, Eyes
Skin, Inhalation
Skin, Inhalation
15 Water or aqueous solutions would be D002
16 Water solutions would be D002.
17
MPTP (l-methyl-4-phenyl-l,2,3,6-tetrahydropyridine); MPPP (l-methyl-4-phenyl-4-propionoxypiperidine).
18
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