Identification of Hazardous Wastes

The regulations of the RCRA classify hazardous wastes into the following categories:

• Listed waste, which is a waste specifically listed by the EPA
• Characteristic waste, which is a waste that is ignitable, corrosive, reactive, or toxic
• Mixed waste, which is waste that has a hazardous component and a radioactive component
• Universal waste, which includes batteries, pesticides, mercury-containing equipment, and lamps (such as fluorescent bulbs)

Each type of hazardous waste has its own set of rules regarding generation, transportation, storage, treatment, and disposal. RCRA specifically names certain materials as being hazardous wastes in 40 CFR 261.31-33. In the additional resources section at the end of this unit, you will find links to the EPA website, which provide useful information about this topic.

A person who generates a solid waste must make an accurate determination as to whether that waste is a hazardous waste. The hazardous waste determination must be made at the point of waste generation, before any dilution, mixing, or other alteration of the waste occurs, as well as at any time in the course of its management that it may have changed its properties such that the RCRA classification of the waste may also have changed.

Generators of hazardous materials can determine if the solid waste material is considered a hazardous waste by asking the following questions in the specific order shown:

1. Is the solid waste excluded? Check if the material is excluded from regulations by consulting 40 CFR 261.4.
2. Is the material a listed waste? Check if the material is a listed waste by consulting 40 CFR 261 Subpart D. If the waste is not listed, move on to the next question. If the waste is listed, there is still the opportunity to demonstrate to the EPA that this particular waste is not hazardous.
3. Does the material exhibit a hazardous characteristic (corrosivity, ignitability, toxicity, or reactivity)? To answer this question, the generator must test the waste according to the methods set forth in 40 CFR 261 Subpart C, or apply knowledge of the hazard characteristic of the waste in light of the materials or processes used.

If the waste is determined to be hazardous, the generator must refer to the regulations for possible exclusions or restrictions pertaining to management of the specific waste.

It is important for anyone who handles hazardous waste to fully understand the different types of waste and how they must be managed. Failure to comply with the specific RCRA regulation for a hazardous waste material may lead to penalties, and may require costly corrective action. Far worse, however, is the potential for improper management to result in a hazardous waste incident that endangers human lives and the environment.

To learn more about RCRA visit our RCRA Hazardous Waste Safety Online Training web page.