Hazardous waste is regulated by the Environmental Protection Agency (EPA) which only allows it to be disposed of at specific sites that have a special permit. The EPA says a waste is hazardous if it is either what the EPA refers to as a “characteristic hazardous waste” or what the EPA refers to as a “listed hazardous waste.”

Characteristic wastes. A waste is hazardous if it has one or more of the following four characteristic properties which are corrosivity, ignitability, reactivity, and toxicity:

• Corrosivity. If the waste is corrosive, it can burn the eyes or skin or body tissue on contact. Corrosives can also corrode standard containers. Examples of corrosive wastes include battery acids, rust removers, and alkaline cleaning solutions.
• Ignitability. An ignitable waste can catch fire or explode easily when exposed to heat or a spark. Most ignitable wastes are liquid in physical form, and examples include paints, cleaners, certain compressed gases, and chemicals that are oxidizers.
• Reactivity. A reactive waste can catch fire, explode, or give off dangerous vapors if it comes in contact with air, water, or certain other substances. Examples of reactive wastes include cyanide plating wastes, metallic sodium and potassium, and waste concentrated bleaches.
• Toxicity. Wastes with the characteristic of toxicity are poisonous, and contact with these wastes can cause severe illness or death. Metals such as lead, mercury, chromium, arsenic, cadmium, and silver are considered toxic, as are chlorinated solvents such as chlorobenzene and cresol.

To determine if a waste exhibits any of the four hazardous waste characteristics, a generator can either apply its knowledge of the waste’s properties or test a sample of the waste as specified in the hazardous waste rules.

Listed wastes. The EPA lists hundreds of specific industrial wastestreams as hazardous. This second type of hazardous waste is from common manufacturing and industrial processes and specific industries. These wastes are either described or listed in the hazardous waste rules. To identify a waste as hazardous, our company has to determine if the waste being generated or managed is any of these “listed” hazardous wastes.

Labeling on-site

Generators using containers or tanks to accumulate hazardous waste on-site have to label or mark the containers with the words “Hazardous Waste” and an indication of the hazards of the contents. The hazard information can be conveyed by any of these ways:

• Indicating the applicable hazardous waste characteristics;
• By hazard communication consistent with the Department of Transportation, or DOT, labeling or placarding;
• Showing an Occupational Safety and Health Administration (OSHA) hazard statement or pictogram; or
• Applying a chemical hazard label consistent with the National Fire Protection Association (NFPA) Code.

This labeling is required in both satellite accumulation areas (SAAs) and central accumulation areas (CAAs). Generators must also indicate visibly the accumulation start date on containers in the CAA. This is the date hazardous waste is first placed in the container. The start date is needed so that the generator can determine how long the waste has been accumulating in the container and ship it off-site at the right time. The length of the accumulation time period is based on whether the generator is a large or a small quantity generator.

Additional preshipment labeling is required before containers are transported or offered for transport off-site.