PPC:

EPA: 530-R-93-004f
NTIS: PB93-922 406

"Unused Formulations of Agent Orange"

(Key Words: Commercial chemical product; hazardous waste

definition; F027)

QUESTION: During the Vietnam War an estimated 44 million pounds
of the herbicide Agent Orange were formulated for use as a
defoliant. Currently there are several United States military
posts in possession of unused formulations of this herbicide.

Upon disposal, would the herbicide Agent Orange be regulated as a
hazardous waste under RCRA Subtitle C?

ANSWER: Unused formulations of Agent Orange would meet the F027
hazardous waste listing when disposed of. The active herbicidal
components of Agent Orange are equal quantities of
2/4/-dichlorophenoxyacetic acid (2,4-D) and
2,4,5-trichlorophenoxyacetic acid (2,4,5-T), which are both
derived from the synthesis of chlorophenols and chlorophenoxy
compounds. The listing description of F027 includes discarded
unused formulations containing compounds derived from tri-,
tetra-, or pentachlorophenol. Since Agent Orange contains a
compound derived from the synthesis of trichlorophenol (i.e.,

2,4,5-T), it is appropriately classified as F027 upon disposal.

(June 1993 Monthly Hotline Report)

RO 13611

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