What is Considered Hazardous Waste?
Hazardous waste is one of the boogeymen of modern life, and the term might paint an immediate picture in most people’s minds of a barrel covered in warning labels. Understanding what constitutes hazardous waste can help businesses comply with regulations, protect their workers and the environment. In this blog, we'll explore what is considered hazardous waste, its classification, and why proper handling is important.
Environmental Impact of Hazardous Waste
There are 35 tons of hazardous waste generated in the U.S. each year. The dangers vary. Some materials are corrosive or flammable, others are unstable, and many cause acute or long-term health effects.
When hazardous waste escapes into the environment, the impact isn’t limited to nearby human communities. It can harm plants and other animals, which can lead to problems with human health. Disruptions to the environment can also cause food shortages, air quality problems, and knock-on economic effects.
We’ve experienced the consequences of hazardous waste mismanagement in the past, such as cancer in the Love Canal area or the Cuyahoga River repeatedly catching on fire. It wasn’t pretty.
That’s why environmental protection laws were enacted in the 1970s to prevent future disasters and clean up the existing ones. Environmental regulations help us safeguard everything from hazardous materials handling to waste management best practices.
The Resource Conservation and Recovery Act (RCRA) of 1976 put the Environmental Protection Agency (EPA) in charge of assigning rules for how to safely handle and dispose of hazardous wastes. Whether the potential harm is immediate (like burns or illness) or through prolonged effects (like cancer or birth defects), the EPA dictates compliance using the same system.
However, before any waste management regulations can be applied to keep humans and the environment safe, someone needs to identify what counts as hazardous waste. And it’s not as easy as you might think.
How To Identify Hazardous Waste in Four Steps
When the EPA determines whether or not a substance should be regulated under RCRA Subtitle C, it uses the following set of questions, known as the Hazardous Waste Identification Process.
Question 1: Is the Material a Solid Waste?
EPA regulations for hazardous waste only apply to what the RCRA defines as “solid waste.”
This part can be confusing because the EPA isn't actually determining if a waste is physically solid. In fact, hazardous waste can also be liquid, semi-solid, or gaseous material that is contained.
So, what is “solid waste”? Generally speaking, it’s a material that will no longer used for its original intended purpose and needs to be reclaimed or processed before it’s reused or discarded.
The RCRA has a specific definition of solid waste as any garbage or refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility, and other discarded material, resulting from industrial, commercial, mining, and agricultural operations, and from community activities. In addition, a material is considered solid waste if it's abandoned, inherently waste-like, discarded military munitions, or recycled in specific ways.
Question 2: Is the Material Excluded from the Definition of a Solid or Hazardous Waste?
The EPA will exclude certain materials from being classified as solid waste. Other materials are still defined as solid waste, but they’re explicitly excluded from being subject to RCRA waste management compliance.
Individual exclusions are established when:
- the material is already subject to regulation under another statute,
- it is impractical or economically infeasible to regulate the waste under RCRA,
- the EPA wants to incentivize recycling of that material, or
- There’s not enough information to justify its regulation.
While there are dozens of solid waste and hazardous waste exclusions, some of the broader categories include:
- Household waste
- Domestic sewage
- Industrial wastewater discharges
- Agricultural waste
- Radioactive waste
- Materials generated during production processes that can be reused in the same processes
Exclusion doesn’t mean that the waste isn’t regulated at all. It may be subject to alternative management standards like the universal waste program.
Question 3: Is The Waste a Listed or Characteristic Waste?
If a material has already been identified as a listed or characteristic waste, it’s automatically considered hazardous waste subject to RCRA Subtitle C.
As the name implies, a listed waste is one that is specifically listed in Section 261 of the Code of Federal Regulations. There are four lists:
- F, for wastes from common manufacturing and industrial processes
- K, for wastes from specific sectors of industry and manufacturing
- P and U, for commercial chemical products that include certain unused chemicals
A characteristic waste is any solid waste with one of four dangerous properties:
- Reactive materials are those that can be unstable under normal or common conditions.
- Ignitable materials are those that have a low flashpoint, can spontaneously catch on fire, or are categorized as oxidizers.
- Corrosive materials are those with a pH less than or equal to 2 or greater than or equal to 12.5.
- Toxic materials are materials that are harmful when ingested or absorbed.
Wastes that have both radioactive and hazardous components are called mixed waste. They’re subject to two different waste management regulations: the RCRA and the Atomic Energy Act.
Question 4: Is The Waste Delisted?
Waste generators can petition to have a specific waste removed from the RCRA's listing if the waste does not have dangerous properties. This process is only allowed to listed wastes, not characteristic wastes.
Once a waste has been delisted, the EPA cannot categorize it as hazardous waste.
What Happens to Hazardous Waste?
Once a waste generator has determined something to be hazardous waste by using the four questions above, they’re responsible for disposing of it in compliance with environmental regulations according to RCRA Subtitle C.
Precautions have to be taken to protect the environment, the general population, and the people who handle the hazardous materials in the process of destroying or storing them.
Check out our article on Hazardous Waste Management to learn more about environmental compliance with RCRA like tracking and proper disposal.
Get Hazardous Waste Training
Workers who clean up, treat, store, and dispose of hazardous waste need to know so much more about keeping themselves safe and protecting public health than they can possibly learn in a blog article.
That’s why OSHA requires HAZWOPER safety training for everyone exposed to hazardous waste in the course of their job.
The type of initial training you need depends on how much contact you’ll have with hazardous substances. Employees who will have minimal contact need HAZWOPER 24, while employees who regularly handle hazardous substances need HAZWOPER 40.
After initial training, all HAZWOPER employees need an annual 8-hour refresher.
We’re an experienced and OSHA-authorized provider, and we offer online and self-paced HAZWOPER courses to help you complete the required training in the most comfortable and convenient manner possible.
We also carry DOT HazMat courses required for anyone involved in the packaging, shipping, and transportation of hazardous materials.
