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Special Waste

Waste Determination

 
 

Special waste does not include hazardous waste. Republic Services provides safe, reliable management services for your special waste, but does not manage or dispose of hazardous waste. The following U.S. EPA guidelines can help you determine which solid wastes are subject to regulation as hazardous waste.

Special Waste does not include waste that is a hazardous waste under the Resource Conservation and Recovery Act (RCRA). RCRA hazardous wastes include listed wastes, characteristic wastes along with wastes that are mixed with or derived from hazardous wastes. Unless subject to an exclusion (See 40 CFR § 261.4), waste that falls within the definition of hazardous waste under any of these categories cannot be handled as a special waste.

Listed Hazardous Waste:
EPA “lists” hazardous wastes that fall into three categories:
  • F-listed wastes:Non-specific source wastes. See 40 CFR § 261.31 for more information
  • K-listed wastes:Non-specific source wastes. See 40 CFR § 261.31 for more information
  • P-and U-listed wastes:Discarded commercial chemical products. See 40 CFR § 261.33 for more information
Characteristic Hazardous Waste
In addition to listed wastes, a waste is a hazardous waste if it exhibits at least one of the following four characteristics:

Ignitability- A substance is ignitable if it displays any of the following properties:
  • A liquid with a flashpoint of less than 60° C (140° F)
  • A non-liquid that is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture, or spontaneous chemical changes, and when ignited, burns so vigorously and persistently that it creates a hazard
  • An ignitable compressed gas;
  • An oxidizer (such as a chlorate or peroxide)
See 40 CFR § 261.21 for more information.

Corrosivity- A substance is corrosive if it displays any of the following properties:
  • An aqueous material with a pH less than or equal to 2 or greater than or equal to 12.5
  • A liquid that corrodes steel at a rate of at least 0.25 inches per year at 55° C (130° F)
See 40 CFR § 261.22 for more information.

Reactivity- A substance is reactive if it displays any of the following properties:
  • Normally unstable and readily undergoes violent change without detonating
  • Reacts violently with water
  • Forms potentially explosive mixtures with water
  • A cyanide or sulfide bearing waste which can generate fumes in a quantity sufficient to present a danger to human health
  • Capable of detonation
  • A forbidden explosive, or a Class A or Class B explosive, as defined in Department of Transportation regulations in 49 CFR Part 173
See 40 CFR § 261.23 for more information.

Toxicity- A substance is toxic if it exceeds the concentrations for contaminants listed in the “Maximum Concentration of Contaminants for the Toxicity Characteristic” table, presented in 40 CFR § 261.24. A specific test, the Toxicity Characteristic Leaching Procedure (TCLP) must be conducted to determine if the waste is classified as toxic.

See 40 CFR § 261.24 for more information.

The "Mixture Rule" states that mixtures of solid waste and listed hazardous waste must be regulated as hazardous waste. There are two ways to determine if a material is regulated under the mixture rule:
In addition to listed wastes, a waste is a hazardous waste if it exhibits at least one of the following four characteristics:
  • If the material is a mixture of solid waste and a hazardous waste, and the mixture exhibits one or more of the characteristics of hazardous waste
  • If the material is a mixture of solid waste and a listed waste
See 40 CFR § 261.3 (a)(iii) and (iv) for more information.

According to the "Derived-From Rule" any solid waste derived from the treatment, storage, or disposal of a hazardous waste is considered hazardous. "Derived from" wastes include sludges, spill residue,, ash, emission control dust, and leachate. See 40 CFR § 261.3 (c) and (d) for more information.

For expert assistance in determining your waste classification, request services online.
  
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