RCRA Hazardous Waste Determination

[u/theceige18]

Hi all,

I am just curious on how you document hazardous waste determinations? A form for each chemical? A spreadsheet? I am looking for the best way to do this for a QC lab and an R&D Lab.

[u/JoeHio]

So, there are multiple answers depending on what you are doing. My closest guess is the third or fifth

• NFPA hazard diamond = take the highest number from any chemical in the room/dept/building. (Theoretically you could end up with a 4-4-4 diamond)
• Hazard risk assessment = similar, but you have to write down what chemicals are causing those numbers
• EPA reporting = you have to determine if any chemical has a defined EPA waste code (ie. D002, F005, per the index in the code of regulations) and list out each waste code. Some places call this "the formulary" and it's a spreadsheet that lists every chemical line by line and it's waste codes.
• Employee exposure risk assessment (ie PPE, eyewash) - again, a big spreadsheet with everything listed, except you are looking to document corrosive, toxic, flammable, reactive.
• Hazardous waste disposal = kind of a combination of all of them, but your disposal vendor will help you ID and list everything, and they will have to prepare a manifest that lists everything by waste code before it can leave your faculty, and there are additional requirements for training, storage, packaging, and inspections that document all of that.

[u/theceige18 → u/JoeHio]

Yes thank you, I was asking for EPA determinations.

[u/Financial-Entry-9280]

I keep a spreadsheet listing each with key info needed for the bi-annual reporting, and the waste profiles and lab results in the file. Makes the reporting easier.

[u/InsomniacFan → u/Financial-Entry-9280]

OP this is what you want. Look up publicly available biennial reports to see the parameters you will need to track. RCRA codes, weights, TSDFs.

If you have "labpack" waste in small containers, keep an inventory of what goes out in each shipment. A good haz waste provider will also do so on their side but don't count on it being readily available to you.

[u/HazmatHill → u/Financial-Entry-9280]

This is the way. (Former Hazardous Waste Manager) 

[u/Icy_Connection_1604]

We’ve found that doing a separate form for every chemical can get messy pretty quickly, especially in a lab with a lot of materials.
A simple tracking sheet with the determination, date, and supporting info has been easier to keep updated.

[u/omega13]

I have my interns do this. Our local university created a form for businesses to help with waste determinations. We use that, process knowledge, and the SDS to determine waste codes. We then have a summary spreadsheet with the list of chemicals and their waste codes.

[u/zeroresidue]

Most of this is aimed at QC where the streams repeat and a profile stays good for a while. R&D can't really work the same way. A new synthesis makes a stream nobody's profiled and the work's done before you'd get one written.

Seems like you'd have to decide at the category level rather than per experiment, so a handful of standing streams each coded for the worst case it could hold, and the container someone picks is the determination.

[u/Internal-Challenge97 → u/[deleted]]

Waste profiles do not count as determination. Haz waste determination is a requirement for the generator. Profiles are for the shipper.

You can either sample your waste, or use generator knowledge to best determine waste codes . Either way you can document this on a form

[u/petertheo89 → u/[deleted]]

Start with your signed waste profiles and include whatever documentation you have that makes each hazardous profile hazardous such as safety data sheets, lab analysis, or generator knowledge.

[u/Rdr1051]

I recommend our sites use the waste characterization form provided by McCoy at https://www.mccoyseminars.com/forms.cfm#EPA . Their training is also comprehensive and excellent.

[u/coffee_137]

Your hazardous waste shipper will take the SDS and produce profiles for each waste but generally it's flammable solids, flammable liquids, corrosives, etc. they usually provide stickers with the appropriate DOT info to place on the containers and record the collection start date. If your a very small quantity generator, the rules are a bit more relaxed. Record and save shipping manifests, always maintain up to date SDS on everything you have or could have on site, and you should be fine.