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What is Hazardous Waste?

To be considered hazardous waste, materials must first meet EPAs definition of solid waste. Solid waste is discarded material, such as garbage, refuse, and sludge, and can be solids, semi-solids, liquids, or contained gaseous materials. Solid wastes that meet the following criteria are considered hazardous and subject to regulations under the Resource Conservation and Recovery Act (RCRA) (40 CFR Part 261):

What is Hazardous Waste?

Waste is considered hazardous if it appears on one of four lists of hazardous wastes published in 40 CFR Part 261 Subpart D. Currently, where more than 400 wastes are listed. Wastes are listed as hazardous because they are known to be harmful to human health and the environment when not properly managed. Even when properly managed, some listed wastes are so dangerous that they are called acutely hazardous wastes. Examples of acutely hazardous wastes include wastes generated from some pesticides that can be fatal to humans even in low doses.

Characteristic Waste

If waste does not appear on one of the hazardous waste lists, it still might be considered hazardous if it demonstrates one or more of the following characteristics:

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Ignitable: Ignitable wastes can create fire under certain conditions (e.g., temperature, pressure) or are spontaneously combustible (40 CFR 261.21). Examples include certain used paints, degreasers, oils and solvents.

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Corrosive: Corrosive wastes are acids or bases that are capable of corroding metal, such as storage tanks, containers, drums, and barrels (40 CFR 261.22). Examples include rust removers, acid or alkaline cleaning fluids, and battery acid.

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Reactive: Reactive wastes are unstable and explode or produce toxic fumes, gases, and vapors when mixed with water (40 CFR 261.23). Examples include lithium-sulfide batteries and explosives.

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Toxic: Toxic wastes are harmful or fatal when ingested or absorbed, or leach toxic chemicals into the soil or groundwater when disposed of on land (40 CFR 261.24).  Examples include wastes that contain high concentrations of heavy metals, such as cadmium, lead, or mercury.

The facility can determine if its waste is toxic by having it tested using the Toxicity Characteristic Leaching Procedure (TCLP), or by process knowledge. A TCLP can be done at a laboratory. It is designed to replicate the leaching process and other effects that occur when wastes are buried in a typical municipal landfill. If the leachate from the waste contains any of the regulated contaminants at concentrations equal to or greater than the regulatory levels, then the waste exhibits the toxicity characteristic.

Process knowledge is detailed information on wastes obtained from existing published or documented waste analysis data or studies conducted on hazardous wastes generated by similar processes. For example, EPAs lists of hazardous wastes in 40 CFR Part 261 (as discussed above) can be used as process knowledge.

Identifying Hazardous Waste

Short line railroads may produce hazardous wastes. It is important to identify and manage hazardous wastes properly to protect facility employees and others in the community, as well as the environment. If the facility is a hazardous waste generator, it is responsible for all steps in hazardous waste management, from generation to final disposal.

The facility can be held liable for any mismanagement of wastes, even after they leave the facility. Therefore, it is important to know the facts. Some of these hazardous wastes are listed in the Waste/Disposal Chart.

Compliance Tip:
If the facility is unsure of whether its wastes are hazardous it can call the RCRA/UST, Superfund, and EPCRA Hotline at 1-800-424-9346, or the Chemical Referral Service Hotline at 1-800-262-8200, which is maintained by the National Chemical Manufacturers Association.

Universal Waste Rule
In 1995, EPA issued the Universal Waste Rule as an amendment to RCRA to reduce the regulatory burden on businesses by providing an alternative and less stringent set of management standards for three types of waste that potentially would be regulated as hazardous:

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batteries (e.g., nickel cadmium, small sealed lead acid) that are spent (i.e., will not be reclaimed or regenerated at a battery recycling/reclamation facility);

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pesticides that have been suspended or canceled, including those that are part of a voluntary or mandatory recall under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and

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mercury thermostats including temperature control devices containing metallic mercury. (Disposal & Site Cleanup of Mercury Spills), What To Do If You Have A Mercury Spill )

Check with the state regulatory agency to see if it has adopted the Universal Waste Rule.
For more information, check website: EPA - Universal Waste

Has the facility determined whether it generates hazardous waste?
If Yes - Facility has gone through the waste determination process or used process knowledge and determined that it does generate hazardous waste. See Waste/Disposal Chart for common hazardous wastes generated by short line railroads.

If No - Facility has determined that it does not generate hazardous waste.
If NA / Not determined - Facility has not gone through this process.

Note: Facility must immediately conduct this process to determine if it is generating a hazardous waste.

Compliance Update:
Universal Waste Rule - On July 6, 1999, EPA issued a final rule called the universal waste rule. This rule provides alternative, less stringent procedures for several types of wastes such as batteries, pesticides, mercury thermostats and lamps including fluorescent. Copies of the rule and corresponding fact sheet can be obtained from the RCRA/UST, Superfund, EPCRA Hotline at 1-800-424-9346.

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