ENVIRONMENTAL HEALTH
S70.41
Revised 10-06
Environmental Health and Safety
335-3041
PDF link
OVERVIEW
Identification of chemical wastes is necessary to determine the proper disposal method. This section includes procedures for identifying dangerous chemical wastes regulated by the United States Environmental Protection Agency (USEPA) and the Washington State Department of Ecology (WDOE).
After identifying the waste chemicals, department personnel submit a Chemical Collection Request (CCR) to Environmental Health and Safety (EH&S). See S70.40 for CCR instructions.
Identification
To determine whether a chemical is a dangerous waste, check whether the waste:
- Is present on the lists of dangerous wastes, or
- Has the characteristics of a dangerous waste, or
- Meets certain criteria which make the substance a dangerous waste.
If the waste generated does not meet any of the criteria or characteristics, and does not appear on any of the lists, it is not a dangerous waste.
Nondangerous chemical wastes may be discarded by drain-disposal, evaporation, or by placement in the regular trash system if doing so will not endanger human health or the environment. NOTE: Do not dispose of chemicals in drains, trash, or by evaporation without prior EH&S approval.
For assistance with identifying wastes or completing CCRs, contact EH&S at 335-3041.
Exceptions
Radioactive Waste
These procedures do not apply to radioactive wastes. The Radiation Safety Office manages radioactive chemicals. Call 335-8916 for assistance or refer to S90.80.
Biohazardous Waste
These procedures do not apply to biohazardous wastes. The Materials and Resources Management Incinerator collects and incinerates biohazardous wastes. Call 335-9075 or 335-3288 for assistance or refer to S80.12.
DEFINITIONS
Acutely Hazardous Waste
Some chemicals are considered to be "acutely hazardous waste" by state and federal agencies. These wastes can be accumulated in a waste generation area only in quantities up to one quart before they must be moved, within three days, to a 90-day accumulation area.
Dangerous Waste
General term applied to chemical wastes regulated under federal, state, and/or local laws.
Responsible Individual
The individual in charge of the workplace where chemical wastes are generated is responsible for determining whether chemicals are regulated wastes.
Waste Generation Area
A waste generation area is a room, portion of a room, a group of interconnected rooms, or an outdoor area where regulated wastes are generated.
WASTE CATEGORIES AND CODES
Dangerous Waste Lists
Dangerous wastes are listed under two main classifications:
Discarded Chemical Products (P001-P205, U001-U411)
This list is used to control old or unused containers of chemicals which might be discarded. Chemicals on this list carry codes with "U" and "P" prefixes. (WAC 173-303-9903)
Dangerous Waste Sources (F001-F039, K001-K161)
This list is used to regulate chemical wastes that are the products of specific processes, such as distillation residues produced from recovery of degreasing solvents. Chemicals on this list have "F" and "K" prefixes (WAC 173-303-9904). For example, spent laboratory solvents, such as toluene, xylene, acetone, and methanol may carry the F003 or F005 codes.
NOTE: F100-F005 listed wastes are common at WSU, but other F-listed and all K-listed wastes are rarely generated by University activities.
Toxic Characteristic Wastes and Codes
For chemicals which are not listed dangerous wastes, the EPA has defined four regulated categories of characteristic wastes. If a chemical meets any of the characteristics, it must be managed as dangerous waste. The characteristics are identified by the terms ignitablity, corrosivity, reactivity, and toxicity.
Ignitability (D001)
If the chemical meets any of the ignitability characteristics indicated below, it is a dangerous waste and carries the D001 waste code. (WAC 173-303-090(5))
NOTE: "Ignitable" substances include flammable liquids, solids, and gases, and oxidizers.
Flammable Liquid
Flammable liquid is defined as any solution which has a flashpoint of less than 60C (140F) as measured by a Pensky-Martens Closed Cup Flash Tester utilizing a specified procedure.
Flammable Solid
Flammable solid is defined as any material which is not a liquid at standard temperature and pressure, and which may ignite as a result of friction or the absorption of moisture, or which may ignite spontaneously.
Flammable Gas
According to federal regulations (49 CFR 173.300), flammable gas is defined as "a compressed gas" in which any of the following occurs:
- Either a mixture of 13% or less (by volume) of the chemical with air forms a flammable mixture or the flammable range of the chemical with air is wider than 12% regardless of the lower explosive limit.
- When igniting the gas at the valve, the flame projects more than 18 inches beyond the ignition source with the valve opened fully, or the flame flashes back and burns at the valve with any degree of valve opening.
- There is any significant propagation of flame away from the ignition source.
- There is any explosion of the vapor-air mixture in a drum.
Oxidizer
An oxidizer is any substance that meets either of the following:
- A substance such as a chlorate, permanganate, inorganic peroxide, or a nitrate, that yields oxygen readily to stimulate the combustion of organic matter; or
- An organic compound containing the bivalent -O-O- structure and which may be considered a derivative of hydrogen peroxide where one or more of the hydrogen atoms have been replaced by organic radicals.
NOTE: A substance meeting these definitions is not considered an oxidizer if it is classified as an explosive, forbidden for transportation, or it is determined that the predominant hazard of the material containing the organic peroxide is other than that of an organic peroxide.
Corrosivity (D002)
If the chemical meets the corrosivity characteristic as indicated below, it is a dangerous waste and carries the D002 waste code. (WAC 173-303-090(6))
Corrosive is defined as:
- An aqueous solution of pH 2 or less, or pH 12.5 or more.
- Any material which corrodes steel (SAE 1020) at a rate of 0.250 inches per year at 55C (130F).
- Any solid or semi-solid material which, when mixed with an equal weight of water, is of pH 2 or less, or pH 12.5 or more.
NOTE: Local city and/or county governments have discharge limits that are much more stringent than those outlined above. For example, any substance poured down the drain within Pullman city limits must be of pH 6-9, and must meet additional requirements.
Contact EH&S for assistance and approval prior to drain disposal.
Reactivity (D003)
If the waste meets the reactivity characteristic as indicated below, it is a dangerous waste and carries the D003 waste code. (WAC 173-303-090(7))
A reactive chemical is any which:
- Is normally unstable and readily undergoes violent change without detonating, or
- Reacts violently upon contact with water, or produces toxic or explosive gases upon contact with water, or
- Is cyanide or sulfide bearing and produces toxic gases when exposed to a solution of pH less than 2 or greater than 12.5, or
- Forms potentially explosive mixtures with water, or
- Is capable of detonation or explosion if subjected to a strong initiating source or heated under confinement, or
- Is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure, or
- Is classified as a Forbidden Material (49 CFR 173.51), Class A Explosive (49 CFR 173.53), or Class B Explosive (49 CFR 173.88) by the U.S. Department of Transportation.
Toxicity (D004-D043)
The toxicity characteristic is defined by concentration of 40 contaminants. If a waste or a constituent of a waste mixture meets or exceeds the concentration limits in this list, the waste must carry the applicable "D" waste code. (WAC 173-303-090(8)(c))
See the EH&S Environmental Services web site to view the Toxicity Characteristics List. Go to:
http://www.ehs.wsu.edu/
Select Environmental Services, then
Select Chemical Waste Management, then
Select Waste Identification Reference.
Toxic Criteria Wastes and Codes
Washington state regulations are more restrictive than the federal laws governing waste management. Therefore, certain kinds of waste are regulated at the state level, but not at the federal level.
The state of Washington adopted the EPA lists and characteristics and added another set of definitions, called toxic criteria wastes. The two types of toxic criteria are:
- Toxicity, with waste codes WT01 and WT02, and
- Environmental persistence, with waste codes WP01, WP02, and WP03.
NOTE: Toxic criteria wastes are not the same as toxic characteristic wastes. Toxic criteria wastes are those designated as dangerous by the state, and are in addition to the toxic characteristic wastes defined by federal law.
Toxicity (WT01, WT02)
If the chemical meets the toxicity criteria as indicated below, it is a dangerous waste and carries the WT01 or WT02 waste code, as appropriate. Refer to the following table to determine whether the chemical meets toxicity criteria. (WAC 173-303-100)
TOXIC CHEMICAL WASTE
Category
TLm96 (fish)
or Aquatic
LC50 ppmOral (rat)
LD50 (mg/kg)Inhalation
(rat) LC50
(mg/l)Dermal
(rabbit) LD50
(mg/kg)Washington
State Waste
CodeX
less than 0.01
less than .5
less than .02
less than 2
WT01
A
0.01-0.1
.5-5
.02-.2
2-20
WT01
B
0.1-1
5-50
.2-2
20-200
WT01
C
1-10
50-500
2-20
200-2000
WT01
D
10-100
500-5000
20-200
2000-20000
WT02
Chemical Mixtures
To determine if a mixture of chemicals is a waste based on toxicity, find the Toxic Category (X, A, B, C, or D) for each chemical in the mixture, and use their percent concentrations in the following formula:
Equivalent Concentration (EC) = sum(X)%
+ sum(A)%
________
10+ sum(B)%
________
100+ sum(C)%
________
1000+ sum(D)%
________
1000where sum (X, A, B, C, or D)% is the sum of all the concentration percentages for a particular toxic category.
For example, a waste contains: 0.01% Aldrin, 1% Endrin, 4% Benzene, 2% Phenol, 5% Dinoseb and 87% Water. Compare the toxicity data with the Toxic Chemical Waste table above to determine the toxic category for each constituent.
Aldrin is Category A, Endrin is Category A, Benzene is category D, Phenol is Category C, Dinoseb is Category B and Water is non-toxic. Place these concentrations in the EC formulae:
EC
=
0%
___
1+ (0.01% + 1%)
____________
10+
5%
___
100+
2%
___
1000+ 4%
___
10000EC
=
0%
+
0.101%
+
0.05%
+
0.002%
+
0.0004%
EC
=
0.1534% Designate the waste based on the equivalent concentration (EC). Use the Equivalent Concentration table below to determine that this waste designates as a dangerous waste, WTO2.
Equivalent Concentration (EC) Waste Designation Less than .001% Not a dangerous waste .001% to 1.0% Dangerous waste (DW), waste code WT02 1.0% or More Extremely Hazardous Waste (EHW), waste code WT01
Persistence
If the chemical meets the persistence criteria as indicated in the (WP01, WP02, WP03) table below, it is a dangerous waste and carries the WP01, WP02, or WP03 waste code, as appropriate. Persistent wastes contain either halogenated organic compounds (HOC) or polycyclic aromatic hydrocarbons (PAH).
Halogenated organic compounds are any organic compounds which, as part of their composition, include one or more atoms of fluorine, chlorine, bromine or iodine which is/are bonded directly to a carbon atom. Polycyclic aromatic hydrocarbons are hydrocarbon molecules composed of two or more fused benzene rings.
PAHs include: acenaphthene, acenaphthalene, fluorene, anthracene, fluoranthene, phenanthrene, benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene, pyrene, chrysene, benzo(a)pyrene, dibenz(a,h)anthracene, indeno(1,2,3-c,d)pyrene, benzo(g,h,I)perylene, dibenzo [(a,e)(a,h), and (a,l)]pyrenes, and dibenzo (a,j)acridine. (WAC 173-303-100)
PERSISTENT WASTE TABLE
If your waste contains...
At a concentration of...
Then your waste's designation is...
State Waste Code
Halogenated Organic Compounds (HOCs)
greater than 1.0%
EHW
WP01
Halogenated Organic Compounds (HOCs)
0.01 to 1.0%
DW
WP02
Polycyclic Aromatic Hydrocarbons (PAHs)
greater than 1.0%
EHW
WP03
Polychlorinated Biphenyls (PCBs)
The state of Washington regulates as dangerous waste any PCB-contaminated material containing more than 2 parts per million (ppm) PCBs.
LOCAL DISCHARGE LIMITS
If a waste does not meet federal or state waste definitions, it still may be prohibited from drain disposal by local city and/or county discharge requirements.
Contact EH&S for assistance and approval prior to drain disposal; telephone 335-3041.
DANGEROUS WASTE LISTS
Listed dangerous wastes are divided into four type lists. These are:
- Acutely Hazardous Wastes List ("P" Codes)
- Discarded Chemical Products List ("U" Codes)
- Dangerous Waste Sources List("F" and "K" Codes)
- Toxicity Characteristics
See the EH&S Environmental Services web site to view the dangerous wastes lists. Go to:
http://www.ehs.wsu.edu/
Select Environmental Services, then
Select Chemical Waste Management, then
Select Waste Identification Reference.