What Constitutes Hazardous Waste?

Hazardous waste is a term thrown around often—but do all of us who use the phrase really know what exactly it refers to? Maybe not. To cut through the confusion and help ensure full compliance, we will look at the exact specifications that constitute “hazardous waste.”

What's So Special About Hazardous Waste?

While it may seem obvious to state that “hazardous waste” is any waste or discarded material that risks human or environmental well-being, the official, technical definition is far more specific regarding what exact wastes apply. In fact, under this definition, the adjective “hazardous” refers to the fact that waste is regulated due to the risks it presents.

These threats can occur through a variety of means, including:

• Fire, which may cause burns or other heat-related injuries
• Explosions, that can cause burns or shrapnel wounds
• Chemicals splashing or spilling, which can cause skin or eye damage

These wastes are reactive, ignitable, corrosive, or otherwise toxic; they are common by- or end-products of manufacturing, lab, and industrial processes.

Mess of Hazardous Waste Regulations

In 2021, 35.9 million tons of hazardous waste was generated by organizations across the US. The harmful nature of hazardous wastes, as well as the frequency with which these wastes are generated across the US, demands heavy regulation. Arguably, the most prominent of the regulations are those outlined in the Resource Conservation and Recovery Act (RCRA).

The exhaustive nature of RCRA hazardous waste guidelines means that, often, hazardous wastes are also referred to as “RCRA-listed” wastes. The full details of these regulatory guidelines can be found in the EPA’s Title 40 – Protection of the Environment. Hazardous waste regulations will also vary locally, regionally, and by state.

Hazardous Waste Types

There are two types of defined hazardous wastes: listed wastes and characteristic wastes.

Listed Wastes are specifically identified on one of four RCRA-defined lists (the F, K, P, and U lists) that outline common manufacturing and industrial process wastes.

• The F List identifies wastes from non-specific sources, and may include, among others:
  • Spent solvents
  • Petroleum refinery wastewater sludges
  • Multisource leachates
• The K List lists source-specific wastes from specific industries. These may include, among others:
  • Veterinary pharmaceuticals manufacturing
  • Iron and steel production
  • Explosives manufacturing
• The P and U Lists identify pure and commercial-grade chemical waste formulations. P List wastes are more acute than U List wastes. There are three requirements for a waste to be P or U listed:
  • The waste must contain at least one of the chemicals on either the P or the U list
  • The chemicals in the waste must be unused
  • The chemicals in the waste must be in the form of a commercial product

Characteristic Wastes are classified based on waste attributes, divided into four main categories:

• Ignitable, wastes which are near-flammable with specific flash points and, under certain conditions, can cause fires
• Corrosive, which depends on the pH of the waste; a waste is considered corrosive if it has a pH of less than 2 or greater than 12
• Reactive, which means the waste material is unstable. These wastes have the potential to explode, ignite, or react to create different materials
• Toxic, based on a specific list of chemicals that the EPA has determined to be hazardous based on previous Toxicity Characteristic Leachate Procedure (TCLP) work

The EPA ultimately makes the call about whether a chemical is hazardous and provides an abundance of information to help make hazard determinations.

Hazardous Waste: Partnership for Safety and Compliance 

Full compliance with all hazardous waste regulations—and full operational safety for yourself, your employees, and your community—starts with knowledge. And how best to ensure you have that exhaustive knowledge than by working with a vastly experienced and dedicated industry partner?

Triumvirate Environmental is one such partner. With more than 30 years of experience in the environmental, health, and safety (EHS) field, we have seen it all—and know the ins and outs of hazardous waste. Start a conversation with us today so we can help you remain safe and compliant.