What is Hazardous Waste

What is Hazardous Waste?

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What Kinds of Wastes are “Hazardous?”

Hazardous wastes include many kinds of discarded chemicals and other wastes generated from commercial, industrial, and institutional activities. Types of waste that are commonly hazardous include cleaning solvents, spent acids and bases, metal finishing wastes, painting wastes, sludges from air and water pollution control units, and many other discarded materials. Hazardous wastes may also include many items that you would not normally think of as being hazardous, such as:

• Batteries (can contain acids and bases, as well as metals like lead and cadmium)
• CRT-based computer monitors (contain lead)
• Thermostats and fluorescent lamps (contain mercury)
• Renovation and demolition waste (can contain lead-based paint)

Not all wastes are regulated as hazardous wastes.  The wastes that are classified as “hazardous wastes” are spelled out in Section 101 of Connecticut’s Hazardous Waste Management Regulations.  Connecticut’s regulations, in turn, incorporate Section 40 CFR, Part 261 of the federal hazardous waste regulations.  [Exit DEEP website]  Hazardous wastes may be divided into two basic groups:  characteristically hazardous wastes and listed hazardous wastes .

Characteristically Hazardous Wastes

These are wastes that are hazardous because they exhibit a certain physical property or characteristic. There are four characteristics that can make a waste hazardous: ignitability, corrosivity, reactivity, and toxicity. A brief description of each of these four characteristics is provided below.

• Ignitable Wastes.  A wastes is ignitable if:  (1) it is liquid and has a flash point below 140 degrees Fahrenheit; (2) it is a flammable solid; (3) it is an ignitable compressed gas; or, (4) it is classified by the U.S. Department of Transportation as an oxidizer.
• Corrosive Wastes.  A waste is corrosive if:  (1) it is aqueous (i.e., water-based) and has a pH of 2.0 or lower (i.e., a strong acid) or 12.5 or more (i.e., a strong alkali); or (2) it can corrode steel at a rate of greater than ¼ inch per year.
• Reactive Wastes.  There are many ways that a waste may be defined as a reactive waste.  To briefly summarize, reactive wastes include wastes that are unstable, react with water or form hazardous mixtures with water, are capable of releasing toxic cyanide or sulfide gases under certain conditions, are explosive, or are capable of detonating under certain conditions.
• Toxic Wastes.  A waste is toxic if it contains any of 40 different hazardous constituents at a concentration equal to or greater than a certain amount.  These 40 constituents include 8 metals, 6 pesticides, 2 herbicides, 10 volatile organic compounds (VOCs), and 14 semi-volatile organic compounds (SVOCs).

For more information on characteristically hazardous wastes, see the DEEP’s Hazardous Waste Determination/Knowledge of Process Fact Sheet and the EPA’s Hazardous Waste Types Web Page [Exit DEEP website].

Listed Hazardous Wastes

These are wastes that are hazardous because they are listed on one or more of four different particular lists of wastes:

• F-Listed Wastes.  This list of wastes includes 28 different wastes, including certain spent solvents, metal finishing wastes, dioxin-containing wastes, chemical manufacturing wastes, wood preserving wastes, petroleum manufacturing wastes, and hazardous waste landfill leachate. 
• K-Listed Wastes.  This list of wastes includes over 100 wastes from specific industrial processes.  The specific processes are in the industries of wood preserving, petroleum refining, primary and secondary metals manufacturing, and the manufacturing of industrial chemicals, inks, pigments, pesticides, explosives, and veterinary pharmaceuticals. 
• U-Listed Wastes.  This list of wastes includes several hundred different commercial chemical products.  Wastes that fall under this listing include only those products that contain the listed constituent as the sole active ingredient.  These wastes include old or off-specification virgin materials that are being discarded, as well as container residues and spill residues of these materials.
• P-Listed Wastes.  This list of wastes includes about 200 different commercial chemical products that are defined as acutely hazardous.  This means that the wastes are especially toxic.  Wastes that fall under this listing include only those products that contain the listed constituent as the sole active ingredient.  These wastes include old or off-specification virgin materials that are being discarded, as well as container residues and spill residues of these materials.

For more information on listed hazardous wastes, see the DEEP’s Hazardous Waste Determination/Knowledge of Process Fact Sheet and the EPA’s Hazardous Waste Types Web Page [Exit DEEP website].

Universal Wastes

This is a special subset of hazardous wastes that are regulated under a streamlined set of regulations called The Universal Waste Rule.  These wastes include:

• Batteries.  Covered batteries include lead-acid batteries, nickel-cadmium batteries, silver cells and mercury-containing batteries.
• Cancelled and recalled pesticides.
• Mercury thermostats and other mercury-containing equipment (e.g., mercury switches, barometers, sphygmomanometers, etc.).
• Mercury-containing lamps.  This includes fluorescent lamps (including compact fluorescent lamps), mercury vapor lamps, and other lamps that contain mercury.
• Used electronics.  This includes desk top and lap top computers, computer peripherals, monitors, copying machines, scanners, printers, radios, televisions, camcorders, video cassette recorders (“VCRs”), compact disc players, digital video disc players, MP3 players, telephones, including cellular and portable telephones, and stereos.

For more information on Universal Wastes, see the DEEP’s Universal Waste Rule Fact Sheet

Used Oil

Just as with Universal Waste, the hazardous waste regulations also have a special set of requirements for used oil.  The term “used oil” means any oil refined from crude oil or synthetic oil, that: (A) has been used and as a result of such use is contaminated by physical or chemical impurities; or (B) is no longer suitable for the services for which it was manufactured due to the presence of impurities or a loss of original properties.  This includes both used and unused oils that are being discarded.  Common examples of used oils include:

• Used crankcase (engine) oil;
• Brake fluid, transmission fluid, and power steering fluid;
• Used gear, chain, and ball bearing lubricants;
• Hydraulic and compressor oils;
• Metalworking fluids (including water-soluble coolants);
• Drawing and stamping oils;
• Heat transfer oils (including quenching oils); and,
• Dielectric fluid (e.g., transformer oil).

For more information on used oil, see the DEEP’s Used Oil Web Page .

Requirements for Other Wastes/Materials

In addition to the hazardous wastes listed above, there are other wastes that, although they are not subject to hazardous waste requirements, must be handled in certain, special ways.

• Household Hazardous Wastes.  These are wastes that are similar to the wastes listed above, but that are generated by residents in their homes while doing routine household activities.  Examples of household hazardous waste include paints, stains, solvents, pesticides, old gasoline and other fuels, etc.  These wastes are just as hazardous as their commercially-generated counterparts, but are not subject to hazardous waste requirements.  However, DEEP encourages household residents to properly dispose of their household hazardous wastes by taking them to a DEEP-authorized household hazardous waste collection center or event.  To find out more about household hazardous waste, see the DEEP’s Household Hazardous Waste Web Page.
• Non-RCRA-Hazardous Wastes (also known as Connecticut-Regulated Wastes).  These are wastes that are not hazardous according to any of the definitions described above, but that are similar in nature to hazardous wastes.  These include some paints (e.g., latex paints), solvents, and other chemicals.  Even though they are not regulated as hazardous wastes, commercial generators of these wastes may not place them in the ordinary trash.  For information on which wastes are considered “Connecticut-Regulated Wastes” and how these wastes must be managed, see the DEEP web page on Non-RCRA Hazardous Wastes.
• Polychlorinated Biphenyls (PCBs).  PCBs (both those being disposed of and those that are still in-use) are subject to a special set of rules that are separate from the hazardous waste regulations.  For details on the proper management of PCBs, see the DEEP’s PCB Web Page.
• Pesticides.  As noted above, discarded pesticides are often regulated as hazardous wastes or as Universal Wastes.  Even if they are not hazardous wastes or Universal Wastes, discarded pesticides would be considered “Connecticut-Regulated Wastes.”  However, there is a separate set of DEEP requirements regarding the registration and use of pesticides.  For more information on these requirements, see the DEEP’s Pesticide Management Program Web Page.

Questions?  If you have questions about hazardous waste, call our toll-free COMPASS hotline at 1-888-424-4193, Monday through Friday, 8:30 a.m. to 4:30 p.m. (except state holidays), or send us an email.

Content Last Updated March 31, 2020

The EPA – and most states with an authorized hazardous waste program – identify two types of hazardous waste:

Listed:

• Hazardous waste from non-specific sources (F-codes).
• Hazardous waste from specific sources (K-codes).
• Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof (P-codes & U-codes).

And…

Characteristic:

The purpose of this article is to explain how EPA identifies the characteristic of Reactivity (D003).

The characteristic of Reactivity is codified in Title 40 of the Code of Federal Regulations at 40 CFR 261.23.  It reads:

a) A solid waste exhibits the characteristic of reactivity if a representative sample of the waste has any of the following properties:

(1) It is normally unstable and readily undergoes violent change without detonating.

(2) It reacts violently with water.

(3) It forms potentially explosive mixtures with water.

(4) When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.

(5) It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.

(6) It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.

(7) It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

(8) It is a forbidden explosive as defined in 49 CFR 173.54, or is a Division 1.1, 1.2 or 1.3 explosive as defined in 49 CFR 173.50 and 173.53.

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(b) A solid waste that exhibits the characteristic of reactivity has the EPA Hazardous Waste Number of D003.

Right from the start – paragraph (a) – the regulation may mislead you into thinking there is a test method for Reactivity because of its reference to “a representative sample of the waste…”.  There is not.  Nowhere in section §261.23 does it refer to a test method for determining the characteristic of Reactivity.  For the characteristic of Reactivity a generator making a hazardous waste determination must rely solely on generator knowledge as allowed by §261.10(a)(2)(ii).

From the EPA website:  "There are currently no test methods available."

So what is a reactive hazardous waste?  It is any solid waste (i.e. any material that is disposed of by being abandoned or recycled, is inherently waste-like, or is a military munition) that exhibits any one of the following characteristics:

Unstable:

It is normally unstable and readily undergoes violent change without detonating.

A waste meeting this characteristic would normally be in an unstable state; defined in general chemistry as compounds that readilydecompose or change into other compounds.  And it also must readily undergo a violent change without detonating (aka exploding).    Note that the trigger for the “violent change”, e.g. pressure, water, heat, &etc. is not specified.  It is clear that they do not mean to include explosives here as they are addressed later in this characterization.

A lithium battery may be a reactive hazardous waste due to its instability (Faxback 11274) unless it has been fully discharged (RO 11229).

I’m no scientist but here’s a good explanation of why lithium batteries sometimes go off:  Here’s why Lithium Batteries Occasionally Catch Fire.

Here is an example of a lithium battery’s instability:

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Lithium batteries may be managed with other hazardous waste batteries as a universal waste.

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

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815.821.1550

Info@DanielsTraining.com

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Water Reactives:

It reacts violently with water.

It forms potentially explosive mixtures with water.

When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.

A waste that performs any one of the above actions when exposed to water must be assigned the characteristic of Reactivity.  Certain elements and substances, e.g. sodium and sodium azide, respectively are known to be water reactive and may be a reactive hazardous waste.  But note the use of subjective and undefined terms such as “violently” and “potentially explosive”.  Also, while the generation of toxic gases, vapors or fumes can be detected or known what can’t be determined from this characterization is what quantity is “sufficient to present a danger to human health or the environment”?  One possible tool for answering this question is to refer to the applicable worker exposure standards of the Occupational Health and Safety Administration (OSHA) for the gas, vapor, or fume generated.  If it is at or near the OSHA maximum exposure limit it may be sufficient to present a danger to human health or the environment(RO14636) (RO12249).

Cyanide or Sulfide Bearing:

It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.

To be a reactive hazardous waste due to this characteristic the waste must:

• Contain either cyanide or sulfide (an inorganic anion of sulfur).  The quantity or concentration is not specified.

And…

• When exposed to pH conditions between 2 and 12.5 – note that this pH range is not characteristic of a D002 corrosive hazardous wastewhich is a liquid with a pH of less than or equal to 2 or equal to or greater than 12.5. – generate dangerous levels of toxic gases, vapors, or fumes.

How can a generator determine a “quantity sufficient to present a danger to human health or the environment.”?

Well, in 1985 EPA provided interim guidance on determining these levels (Faxback 11091).  However, this guidance was withdrawn in 1998 and has not been replaced (Faxback 14177).  So it looks like you’re on your own.

Explosives:

It is capable of detonation or explosive reaction if it is 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 173.54, or is a Division 1.1, 1.2 or 1.3 explosive as defined in 49 CFR 173.50 and 173.53.

Note the three separate definitions of an explosive.

1.  IT COULD EXPLODE IF TRIGGERED…

The first is merely “capable” of detonation (an explosion at faster than the speed of sound) or explosive reaction which is not quite the same as an explosion.  Further, the waste will only begin detonation or explosive reaction if it is subjected to a strong initiating force or heated under confinement.

So then, what about aerosol cans and other compressed gas cylinders?  Could they be a D003 reactive hazardous waste solely because of their capability of detonation or explosive reaction when heated or otherwise punctured?  The answer from EPA, surprising to me, was “maybe”.  In 1987 EPA stated that a discarded aerosol can is a reactive hazardous waste due solely to the propellent and not any other waste it contains (RO13027).  However, six years later in 1993 EPA refused to answer the question: “At this time, the Agency is not able to determine whether various types of cans that may have contained a wide range of products are reactive.”  The Agency went on to state that nearly empty steel aerosol cans are subject to the scrap metal exemption at 40 CFR 261.1(c)(6) and as such may even be punctured and drained without a permit (RO11782).

You may manage your hazardous waste aerosol cans under the scrap metal exemption.

My interpretation is that unless RCRA Empty, an aerosol can will – at a minimum – be a D003 reactive hazardous waste due to the contents or the propellant being under pressure and capable of detonation if exposed to…

a strong initiating source:

Or heated under confinement:

But as the generator you must determine for yourself if your non-empty aerosol cans display the characteristic of Reactivity.

Some states, such as California and Minnesota, allow non-empty aerosol cans to be managed as a universal waste.

But I may be wrong because even though EPA has refused to directly answer if aerosol cans are a reactive hazardous waste, it has stated that ammunition up to and including 0.50 caliber does not display the characteristic of Reactivity (RO 13712).  So, if ammunition is not a reactive hazardous waste due to its explosive nature perhaps aerosol cans aren’t either.

We have two more types of explosives to consider…

2.  MORE LIKELY TO EXPLODE WITHOUT A TRIGGER…

Another explosive characteristic is one that is “readily capable” of exploding at standard temperature and pressure.  Note that this is a much more reactive material since it is “readily capable” instead of just merely “capable” and it does not require heat or a strong initiating source.

3.  FORBIDDEN AND THE BIG BOOMERS…

And finally, it is a specified type of explosive as defined by the Hazardous Material Regulations of the USDOT/PHMSA.  So let’s take a look at them:

• Explosives that are forbidden in transportation by USDOT/PHMSA are identified at 49 CFR 173.54.  They include but are not limited to nitroglycerin, loaded firearms and toy torpedoes.  Simply refer to this
• 49 CFR 173.50 identifies the six different divisions of hazard class 1 Explosives regulated by the HMR.  The three divisions that will be a reactive hazardous waste upon disposal are the most dangerous:

(1) Division 1.1 consists of explosives that have a mass explosion hazard. A mass explosion is one which affects almost the entire load instantaneously.

(2) Division 1.2 consists of explosives that have a projection hazard but not a mass explosion hazard.

(3) Division 1.3 consists of explosives that have a fire hazard and either a minor blast hazard or a minor projection hazard or both, but not a mass explosion hazard.

Most consumer fireworks are a Division 1.4 Explosive and therefore would not display the characteristic of Reactivity when discarded.

Note:  A consumer firework that is a Division 1.4 Explosive may not display the characteristic of Reactivity but it may be a hazardous waste due to other characteristics such as Toxicity.

Commercial fireworks (the kind you see at a big show) and military munitions will likely be classified as a Division 1.1, 1.2, or 1.3 and will therefore be a reactive hazardous waste if discarded unused.

49 CFR 173.53 does not identify any new explosives not already identified in §173.50.  Instead it cross-references the current classification system of hazard class and division with a format used by USDOT/PHMSA prior to January 1, 1991 and still used by some states or other regulatory agencies.  Example:

• Division 1.1 = Class A explosives
• Division 1.2 = Class A or Class B explosives
• Division 1.3 = Class B Explosives
• Division 1.4 = Class C explosives
• Division 1.5 = Blasting agents
• Division 1.6 = No applicable hazard class

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

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815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

If you’re looking for clear-cut thresholds or approved analytical methods for the determination of the characteristic of Reactivity, you won’t find it here.  The determination of a reactive hazardous waste relies heavily on your knowledge of the process generating and the waste itself at the point of generation.

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