on April 15, 2022 in Chemical Disposal
Anyone who works with chemicals as part of their day-to-day responsibilities knows the proper safety protocols when handling hazardous chemical waste. Understanding the appropriate disposal protocols is just as important. Under the Resource Conservation and Recovery Act (RCRA), chemical waste is regulated by the Environmental Protection Agency (EPA) to protect the environment, and there are stringent regulations governing chemical disposal.
There are generally four categories of chemical waste that will determine the proper disposal plan:
Hazardous Chemical Disposal:
Chemicals exhibiting a ‘hazardous’ characteristic, listed by Federal or State regulations (see list below), should be handled as hazardous wastes. Environmental regulations apply to hazardous wastes because of their potential to harm people or the environment. This is the most environmentally beneficial method of handling this chemical waste.
Non-hazardous Chemical Disposal:
Chemicals that do not exhibit state or federal hazardous characteristics and are not listed as hazardous wastes are not always safe for disposal in regular trash or the sink. Specific hazardous waste management rules do not apply when a chemical is collected as non-hazardous waste.
Universal Waste Disposal:
Several types of chemical waste have been deregulated to some degree since they are so widely distributed. Although management regulations still exist, they are less stringent than hazardous waste regulations.
Sink or Trash Disposal:
Few chemical wastes are unregulated and can be poured into sinks or disposed of in the trash. These chemicals should always be confirmed before disposing of this way.
Next, determine if your chemicals are classified as hazardous waste. If a waste appears on one of four lists (F, K, P, or U) in title 40 of the Code of Federal Regulations (CFR), part 261, it is considered hazardous waste. Once you pinpoint what list your chemical is on, you can figure out a proper disposal.
The F List
The F-list identifies hazardous wastes from common industrial and manufacturing processes. Many different approaches in different sectors can generate these wastes, known as non-specific wastes. The seven types of manufacturing and industrial operations that create them can be divided into seven categories:
- Spent solvent wastes
- Electroplating and other metal finishing wastes
- Dioxin-bearing wastes
- Chlorinated aliphatic hydrocarbons production
- Wood preserving wastes
- Petroleum refinery wastewater treatment sludges
- Multisource leachate
The K List
Known as source-specific wastes, hazardous wastes on the K-list originate from specific industries and manufacturing sectors. To qualify as a dangerous k-listed waste, a waste must fall into one of the 13 categories and match one of the detailed descriptions of the waste. This listing specifies specific solid wastes from particular industries as hazardous wastes. 13 industries generate K list wastes:
- Wood preservation
- Organic chemicals manufacturing
- Pesticides manufacturing
- Petroleum refining
- Veterinary pharmaceuticals manufacturing
- Inorganic pigment manufacturing
- Inorganic chemicals manufacturing
- Explosives manufacturing
- Iron and steel production
- Primary aluminum production
- Secondary lead processing
- Ink formulation
- Coking (processing of coal to produce coke)
On the P-list are acute hazardous wastes, which are wastes from discarded chemical products. U-lists identify hazardous wastes from discarded commercial chemical products.
These lists are designated as hazardous waste pure and commercial grade formulations of certain unused chemicals being disposed of. The following three criteria must be met for waste to be listed as P- or U-waste:
- The waste must contain one of the chemicals listed on the P or U list;
- The chemical in the waste must be unused; and
- The chemical in the waste must be in the form of a commercial chemical product.
- “EPA defines a commercial chemical product for P, and U list purposes as a chemical that is either 100 percent pure, technical (e.g., commercial) grade, or the sole active ingredient in a chemical formulation.” The entire list can be seen here: https://www.epa.gov/environmental-topics/land-waste-and-cleanup-topics
A waste’s characteristics must also be considered when determining whether it is hazardous. The listing is not always a plausible way to account for mixtures. RCRA defines hazardous waste as having the following characteristics:
Every container of regulated chemical waste must meet the following minimum requirements per federal and state regulations.
Closure: It is imperative that chemical waste containers are sealed tightly at all times; unless someone is filling the container with waste. You can only accomplish this by fitting the container with a tight-fitting screw cap.
Condition: Make sure the chemical waste containers aren’t cracked, leaky, or corroded.
Compatibility: Chemical waste containers must be compatible with the waste they contain and resistant to their waste.
Size: Containers must not exceed 55 gallons. Suppose a quart of P-listed chemicals has been generated in a Satellite Accumulation Area. In that case, the waste inside the container cannot exceed one quart (even if the container itself is larger).
Labeling: Every container within a Satellite Accumulation Area must be marked. The hazardous waste generators’ responsibility is to mark their containers clearly in satellite accumulation areas with words identifying the hazards within the containers and the word “Hazardous Waste.”
The final step in a proper chemical disposal plan is keeping accurate records. It is necessary to include a uniform hazardous waste manifest with most hazardous waste shipped away from sites to track waste streams properly.
Hazardous waste manifests provide information about the transport of hazardous waste from the point of generation through transportation, storage, and disposal.
The uniform hazardous waste manifest (EPA Form 8700-22) and its continuation sheet (EPA Form 8700-22A) are required to be used for both interstate and intrastate transportation of hazardous waste by generators and transporters of hazardous waste and by owners and operators of hazardous waste treatment, storage, or disposal facilities (TSDFs).
- Understand what classification your chemicals are
- Determine which list your chemical falls under.
- F List
- K List
- P List
- U List
- Know your chemical waste characteristics
- Have proper containers for your chemical
- Keep good records
Dealing with the aftermath of working with chemicals can feel overwhelming. But with this beginner’s guide to chemical disposal, you can now begin to understand how vital it is to properly dispose of chemicals so we can keep our environment and your facility safe.
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