Materials are classified as hazardous waste based on the manner in which they are disposed and the hazards their disposal will present to human health and safety, as well as potential environmental damage. For a chemical to become a hazardous waste, it must first meet the regulatory definition of "Solid Waste".
The Environmental Protection Agency (EPA) defines a Solid Waste as any “garbage, refuse, sludge and other discarded material” including:
- Contained gaseous materials
resulting from industrial, commercial, mining, and agricultural operations.
The definition of Solid Waste has more to do with the disposition of the material, rather than the physical state of the material.
Hazardous Waste: A solid waste is classified as a hazardous waste if it is “listed” or has a “hazardous characteristic” as defined in 40 Code of Federal Regulations (CFR) 261, and 6 New York Codes of Rules and Regulations (NYCRR) 371. Hazardous wastes all have their own identification codes. For example; D001 is the code for characteristic Ignitable wastes, while F001 is the code for listed spent solvents used in degreasing operations.
5.1 Listed Hazardous Wastes (F, K, U, and P lists) (Top)
The EPA has 4 lists of hazardous wastes. DEC has the same listing as the EPA, with one additional list for Polychlorinated Biphenyl (PCB) wastes. Any waste with a contaminant meeting the definition of any of these lists is considered hazardous waste regardless of the hazardous characteristics. The Lists are found in 40 CFR 261 Subpart D and 6 NYCRR 371.4.
5.1.1 F-Listed Waste (Top)
These wastes are known as “Non-Specific Source Wastes.” They are mostly spent solvents and wastewaters. Many of Cornell’s laboratories generate these spent solvent wastes.
5.1.2 K-Listed Waste (Top)
These wastes are " Specific Source Wastes" Most are from industrial process wastes and are very specific to a particular industrial process. For example; K050…Heat exchanger bundle cleaning sludge from the petroleum refining industry. Cornell does not generate any K-Listed Waste.
5.1.3 U and P Listed Waste (Top)
U and P listed wastes are discarded commercial chemical products, off-specification species, container residues, and spill residues thereof. In general, they are unused materials containing only one active ingredient. Cornell generates many of these wastes during lab cleanouts or disposal of outdated chemicals.
The main differences between U-Listed and P-Listed waste is that the P-Listed wastes are acutely toxic and the empty containers which held their material must be triple rinsed, and the rinsate collected and shipped as hazardous waste. Alternatively, using a CU Hazardous Waste label, manage the empty bottle as P-listed hazardous waste ensuring the listed chemical is identified on the label. The storage time requirements for generators are more stringent when storing P-Listed wastes.
5.1.4 Polychlorinated Biphenyls (PCBs) (Top)
The DEC list for PCB wastes includes various PCB’s, PCB transformers, articles, and other PCB wastes. They are not EPA listed hazardous waste but are regulated by New York State as hazardous waste in 6 NYCRR 371.4.
5.2 Characteristic Waste (Top)
In brief, the following are the characteristics which will cause a solid waste to be regulated as “hazardous waste”:
5.2.1 Ignitability (Top)
- A liquid other than an aqueous solution containing less than 24 % alcohol by volume, having a flashpoint of less than 140°F.
- A non-liquid capable under standard temperature and pressure of causing fire through friction, spontaneous combustion, and when ignited, burns so vigorously and persistently that it creates a hazard.
- It is an ignitable compressed gas.
- It is an oxidizer.
5.2.2 Corrosivity (Top)
- It is aqueous and has a pH of less than or equal to 2 or greater than or equal to 12.5.
- It is a liquid and corrodes steel at a rate greater than 0.250 inch per year.
5.2.3 Reactivity (Top)
- It is normally unstable and readily undergoes violent change without detonating.
- It reacts violently or forms potentially explosive mixtures with water.
- When mixed with water, it generates toxic gases, vapors or fumes that present a danger to human health or the environment.
- It is a cyanide or sulfide bearing waste that can generate toxic gases vapors or fumes that present a danger to human health or the environment when exposed to pH conditions between 2 and 12.5.
- It can detonate or explode if subjected to a strong initiating source or if heated under confinement.
- It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.
It is a forbidden explosive as defined in 49 CFR 173.
5.2.4 Toxicity (Top)
A solid waste exhibits the characteristic of toxicity if, using the EPA’s Toxicity Characteristic Leaching Procedure (TCLP) test method, the extract from a representative sample of the waste contains any of the contaminants listed in Table 1 of 40 CFR 261.24 at the concentration equal to or greater than the respective value given in the table. There are 40 contaminants listed in Table 1. Most of these are heavy metals, organic solvents, and pesticides.
5.3 The Mixture Rule (Top)
If you have a characteristic hazardous waste and it is inadvertently mixed with a nonhazardous waste, the mixture will be considered hazardous waste only if it retains the hazardous characteristic.
If you have a nonhazardous waste, e.g. used oil, and you contaminate it with a listed hazardous waste, e.g. F005 spent solvent; the entire waste will be classified as F005 listed hazardous waste.
A few wastes are listed only because they are ignitable or reactive. In these cases, if the resulting mixture is no longer ignitable or reactive, then the mixture is not considered a listed waste.
Examples: Spent solvents (F003), such as methanol or acetone, are listed hazardous wastes and are ignitable. If these solvents are unintentionally mixed with a non-ignitable nonhazardous waste, the mixture will still be considered hazardous, unless the mixture is not ignitable.
Please note that intentional dilution of a hazardous waste is not allowed without a permit.
5.4 The Derived From Rule (Top)
Waste generated (derived) from the treatment, storage, or disposal of a listed hazardous waste, including sludge, spill residue, ash, emission control dust, or leachate, is considered a listed hazardous waste.
Example: Any ash or residue left from the incineration process at a hazardous waste incinerator is considered hazardous waste.