Why is this important?
- If your program is anywhere near the cutoff limits for Small Quantity Generator or Conditionally Exempt Small Quantity Generator, careful waste identification may bring you below the limit and simplify your life.
- If your community is concerned about the amount of hazardous waste coming from the campus, accurate identification will generally lower the quantities that you need to report—and maybe eliminate the need to report.
Basic Principles
- Many non-RCRA chemical wastes are best handled as RCRA waste. Decisions on counting waste and managing it are not always congruent under present rules.
- Don't count non-RCRA waste against your generator status, even if it goes into the same labpack with RCRA waste for treatment or disposal.
- Don't mix acute hazardous waste with other materials for disposal because the entire mixture becomes acute hazardous waste.
Identification Logic
There are many subtle exceptions and inclusions in the RCRA rules, but the following principles serve quite well for nearly all lab waste from higher education. See text below or the flow chart.
A waste item must pass all of the following tests to be non-RCRA. Use your knowledge about the source of the waste to help answer the questions. If in doubt, you may need to supplement your knowledge with chemical analyses.
- Is it unused with a single active ingredient? Note: Preservatives, propellants, solvents and fillers are not active ingredients. Check the P and U lists.
- Did it come from a simulated or actual industrial process? (rare from labs, more likely from art studios, maintenance and shops)? Check F and K lists.
- Is it a used solvent mixture? Check F list, specifically F002 through F005.
- None of the above? Check for characteristic on D list.
- If it passes all of these tests, it is not RCRA regulated.
