OSU Hazardous Waste Determination Process
“Is my waste a hazardous waste regulated under the Resource Conservation and Recovery Act (RCRA)?” This is one of the most common and basic RCRA questions and is the key to the RCRA hazardous waste program. If something is not a hazardous waste, it is not regulated under RCRA. Proper identification of a hazardous waste can be a difficult and confusing task, as the RCRA regulations establish a complex definition of the term “hazardous waste.” To help make sense of what is and is not a hazardous waste, this module presents the steps involved in the process of identifying, or “characterizing,” a hazardous waste.
With the new Hazardous Waste Generator Improvement Rule, 40 CFR 262.11 – Hazardous waste determination and recordkeeping: Persons who generate solid waste MUST determine whether that waste is listed as hazardous waste and/or exhibits hazardous waste characteristic(s) at the point-of-generation. …Under the new version of the rule, you must document the waste determination process and keep those records. Hazardous waste determinations can be complicated, and must be done for every waste stream generated at a facility. So how can we do this effectively, and without sending every person working in a laboratory to full RCRA training?
Our solution here at Oregon State University was to develop a simple process form that P.I’s and lab personnel complete, return to the EH&S Haz-Waste Team, where we look over the process, the waste generated and complete a printable form with the official waste determinations and a sample of the Hazardous Waste Label that would go on the appropriate container for collection and disposal. This form is signed by an appropriate EH&S personnel, then a hard copy and electronic copy is sent to the lab where the waste is generated. The written copy is then placed in the “Chemical Labeling Station” mounted on the wall in the lab. We are also developing an online library of waste determinations for common processes that are readily available for printing.
Conducting an adequate determination for each waste stream and properly documenting that determination will help our institution stay in compliance and avoid costly mistakes. Adequate determinations are the foundation of any good hazardous waste management program and will help reduce management and disposal costs.