In accordance with EPA and DEP regulations, hazardous chemical waste is either characteristic waste or listed waste. The EPA identifies and lists hazardous waste in 40 CFR 261 and MA DEP identifies and lists hazardous waste in 310 CMR 30.
If a waste stream exhibits any of the four characteristics stipulated in these regulations, it is a characteristic hazardous waste. The four characteristics are ignitability, corrosivity, reactivity, and toxicity. MA, 310 CMR 30.120 establishes the criteria for each of these characteristics. Generally speaking, ignitable waste has a flash point of less than 60 degrees Centigrade. Corrosive waste has a pH less than or equal to 2, or greater than or equal to 12.5. A waste exhibits the characteristic of reactivity if it has any of the properties stipulated in 310 CMR 30.124. And a waste exhibits the characteristic of toxicity if the Toxicity Characteristic Leaching Procedure (TCLP) shows any of the contaminants listed in 310 CMR 30.125 Table 1 at a concentration equal to or greater than the regulatory level. Toxic waste streams are assigned EPA Hazardous Waste Numbers D004-D043.
It is very common to see ignitable waste and corrosive waste being generated in research and development laboratories. In cases where it is questionable if a liquid waste has a flash point below 140 degrees Fahrenheit, testing can be conducted to determine if the steam is actually ignitable waste. When establishing waste stream information profiles with your chemical waste hauler, it is essential to have each waste stream characterized appropriately. If there is any doubt or if your facility is a Large Quantity Generator of hazardous waste, each stream should be analyzed.