Hazardous Chemical Waste
Hazardous Waste is a very specific term that is defined by the EPA. The 1976 Resource Conservation and Recovery Act (RCRA) provide the definition of hazardous (chemical) waste for which EPA has issued regulations. The waste is considered hazardous if due to its quantity, concentration, or physical and chemical characteristics may
- cause, or significantly contribute to, an increase in mortality or an increase in serious or incapacitating illness; or
- pose a substantial present or potential threat to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.
The disposal of regulated waste and other unwanted chemicals has become increasingly complicated. The United States Environmental Protection Agency (EPA) and the Pennsylvania Department of Environmental Protection (PADEP) are the primary regulatory agencies who oversee the accumulation, treatment and disposal of regulated waste in Pennsylvania.
All personnel should treat all waste chemical solids, liquids or containerized gases as hazardous waste unless a specific chemical waste has been confirmed to be a non-hazardous waste by EHRS. A chemical becomes a “waste” when you no longer intend to use it, regardless of whether or not it has been used or contaminated. In addition, spilled chemicals and absorbent materials used to clean the spill should be disposed as hazardous waste.
To ensure consistency with the hazardous waste determination process, all personnel should treat all waste chemicals as a hazardous waste and allow EHRS to make the final determination as sated above.
The EPA groups hazardous waste into two categories: characteristic waste (physical properties) and listed waste (specifically identified by technical name). The EHRS also manages the wastes that may not be defined by the EPA as hazardous, but present a significant hazard to warrant handling them as a hazardous waste.
Wastes exhibiting any of these characteristics are considered hazardous.
1. Ignitability (EPA code D001) - Ignitable wastes are spent materials exhibiting one or more of the following characteristics:
- Liquids other than aqueous solutions containing less than 24% alcohol by volume, that have a flash point less than 140° F (60° C.),
- Non-liquids that are capable of causing fire by friction, absorption of moisture, or spontaneous chemical change and when ignited burn vigorously and persistently to create a hazard.
- Flammable (Ignitable) compressed gases.
- Oxidizers: substances that yield oxygen readily to stimulate combustion
Examples: Most common organic solvents, gases such as hydrogen and certain nitrate salts.
2. Corrosivity (EPA Code D002) - Corrosives are materials meeting one or more of the following criteria:
- Aqueous solutions with pH equal to or less than 2 or greater than 12.5. Note: wastes with pH ranges 2-6 and 11-12.5 are also managed as hazardous waste because of sewer discharge regulations and SARA Title III requirements.
- Liquid substances which corrode steel (SAE 1020) at a rate greater than 6.35 millimeters (0.250 inches) per year at a test temperature of 55ºC (130ºF.)
Examples: Most common laboratory acids and bases as well as some amines and certain metal salts
3. Reactivity (EPA code D003) - Reactive materials are defined as materials meeting one or more of the following criteria:
- Is normally unstable or reacts violently (without detonating.)
- Reacts violently with water.
- Forms explosive mixtures with water.
- Materials which, when mixed with water, generate toxic gases, vapors, or fumes dangerous to human health or the environment.
- Contains cyanide or sulfide and generates toxic gases, vapors or fumes between pH 2 and 12.5.
- Materials capable of detonation or explosive reaction when subjected to a strong initiating source or heated in confinement.
- Capable of detonation or explosive
- It is a forbidden explosive as defined by the Department of Transportation.
Examples: Alkali metals, peroxides and cyanide and sulfide compounds.
4. Toxicity (EPA code D ( D004 thru D043))- Toxicity is established through the Toxicity Characteristic Leaching Procedure (TCLP), which measures the tendency of certain toxic materials to be leached (extracted) from the waste material under conditions that the waste would be exposed to in a landfill. A waste demonstrates a TCLP characteristic if a representative sample taken according to a prescribed EPA extraction procedure contains any of the following substances in excess of concentration limits.
Heptachlor (and its epoxide)
Methyl ethyl ketone
The levels at which these chemicals are regulated varies from 0.2 ppm to 400 ppm. These levels are very low. A waste should be considered as hazardous if the waste contains one or more of the components listed above unless a TCLP analysis has been conducted and it shows the waste to be below the regulatory limit. All TCLP analysis results must be approved by EHRS.
The eight metals listed above are regulated in both their pure forms and as compounds.
EPA regulates approximately 700 commercial or off-specification chemical waste streams, or their spill residues which must be handled as hazardous waste due to their acute or chronic toxicity. These specifically listed wastes are designated as F, K, P or U list. Acutely hazardous waste is designated by an H list hazard code and all P listed waste.
The list includes waste that is either a process waste or a discarded commercial product. A process waste is any waste that, by virtue of some use, process or procedure, no longer meets the manufactures original product specification. A discarded commercial chemical product is the original (virgin) material in the original container that is unwanted, unused or outdated.
- F-List (EPA Code F (F001-F039)) - The F list addresses waste from nonspecific sources ( ex. spent solvents) and is broken down into several subcategories (or codes.) Five codes that are commonly applicable at Temple are:
- F001 Code-spent solvent mixtures and blends used for degreasing which contained, before use, a total of ten percent or more (by volume) of one or more of the following halogenated solvents:
- F002 Code-spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following halogenated solvents:
- F003 Code-spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following non-halogenated solvents:
Methyl isobutyl ketone
- F004 Code-spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following non-halogenated solvents:
Cresols and cresylic acid
- F005 Code-spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of the following non-halogenated solvents:
Methyl ethyl ketone
- K-List (EPA Code K) - This list contains waste from specific sources such as factories and industries. These codes generally do not apply to Temple University.
- P (EPA Code P) & U (EPA Code U) –List-The P and U-listed hazardous waste are pure and commercial grade formulations of specific unused chemicals that are considered waste. Unused chemicals may be considered waste because they are no longer needed, they are spilled, outdated or they are off-specification.
Acutely hazardous waste - Certain listed hazardous waste are considered to be acutely toxic to human health and the environment and are further described as “acutely hazardous waste.” All P listed waste is considered to be acutely hazardous waste. All other listed waste that have an “H” designation after the chemical name are also considered to be an acutely hazardous waste.
Chemicals with sufficient mutagenic, teratogenic, carcinogenic, reproductive or toxicity hazards or those chemicals that may be detrimental to the environment may warrant special handling (e.g. Ethidium bromide). In general, waste streams greater than 1 ppm of these waste should either be deactivated in the laboratory/work area or processed through EHRS.
Determining if a waste is hazardous can be a difficult and time consuming task. Therefore, it is Temple University policy that all chemicals are assumed to be hazardous and must be managed through EHRS unless prior approval is granted or stated in this guide.
Strict sewer, air emissions, and landfill regulations require that hazardous waste is not disposed of through the drains, evaporated in fumehoods or disposed of in the regular trash. Contact EHRS if you need assistance in determining the proper disposal method of your unwanted material.