Last Revised: April 22, 2020
IMPORTANT! As a result of recent changes to US EPA regulations regarding hazardous waste disposal, a hazardous waste determination must be performed in the laboratory in which the waste is generated. EHRS has updated Penn’s chemical waste label to reflect this change and guide you through the process. The required chemical waste labels are yellow and any old green labels should be discarded. Sections 1 and 2 of the new label must be completed in the lab when the first drop of waste is added to a container. The remaining sections must be completed prior to requesting a waste pickup.
EHRS understands that this is a new procedure and can be a challenging task. Please contact the EHRS waste group anytime with questions at 215-898-2580.
Please review the FAQs below:
1. What is a Hazardous Waste Determination?
A hazardous waste determination is the process of evaluating the characteristics and chemical constituents of a specific chemical waste. If the waste meets any of the EPA definitions that are described below then the material is regulated by the EPA as a hazardous waste.
2. What is a Hazardous Waste?
A hazardous waste is a solid, liquid, or gaseous material that displays either a “Hazardous Characteristic” or is specifically “listed” by name as a hazardous waste. Characteristic wastes are not listed specifically by their chemical name but they are regulated as hazardous wastes because they exhibit one or more of the four hazardous characteristics shown below.
FLAMMABLES / IGNITABLES
- A liquid with a flash point of <140˚F
- A solid that can cause a fire and sustain combustion
- An ignitable compressed gas or aerosol can
- An oxidizer
CORROSIVES (ACIDS/BASES)
- Aqueous solutions with a pH less than or equal to 2 or greater than or equal to 12.5.
- Examples: hydrochloric acid, nitric acid, and sodium hydroxide
REACTIVES
- Materials that react violently or generate toxic fumes when mixed with water
- Cyanide or sulfide bearing wastes which evolve toxic fumes when mixed with acids or bases
- Materials that are normally unstable or explosive
- Examples: sodium metal, reactive sulfides, potassium cyanide and picric acid
EPA TOXICITY METALS
Metals – Reagents and items/debris contaminated with or containing any of the following:
The TOXICITY characteristic applies to wastes that have the potential to contaminate groundwater if improperly disposed of. These materials are regulated as hazardous wastes due to their potential to leach out specific toxic substances in a landfill. There are currently 40 contaminants on the list that include certain metals, pesticides and organic compounds. These chemical constituents are listed in the two tables below.
EPA TOXICITY METALS
Metals – Reagents and items/debris contaminated with or containing any of the following:
|
EPA HW No. |
Contaminant |
Level (mg/L) |
|
D004 |
Arsenic (As) |
5.0 |
|
D005 |
Barium (Ba) |
100.0 |
|
D006 |
Cadmium (Cd) |
1.0 |
|
D007 |
Chromium (Cr) |
5.0 |
|
D008 |
Lead (Pb) |
5.0 |
|
D009 |
Mercury (Hg) |
0.2 |
|
D010 |
Selenium (Se) |
1.0 |
|
D011 |
Silver (Ag) |
5.0 |
Examples include: Mercury containing compounds, elemental mercury, silver nitrate, lead nitrate & chromic acid.
EPA TOXICITY Organics – Reagent and items/debris contaminated with or containing any of the following:
|
EPA HW No. |
Contaminant |
Level (mg/L) |
EPA HW No. |
Contaminant |
Level (mg/L) |
|
D018 |
Benzene |
0.5 |
D032 |
Hexachlorobenzene |
0.13 |
|
D019 |
Carbon tetrachloride |
0.5 |
D033 |
Hexachlorobutadiene |
0.5 |
|
D020 |
Chlordane |
0.03 |
D034 |
Hexachloroethane |
3.0 |
|
D021 |
Chlorobenzene |
100.0 |
D013 |
Lindane |
0.4 |
|
D022 |
Chloroform |
6.0 |
D014 |
Methoxychlor |
10.0 |
|
D026 |
Cresol |
200.0 |
D035 |
Methyl ethyl ketone |
200.0 |
|
D023 |
o-Cresol |
200.0 |
D036 |
Nitrobenzene |
2.0 |
|
D025 |
p-Cresol |
200.0 |
D037 |
Pentachlorophenol |
100.0 |
|
D024 |
m-Cresol |
200.0 |
D038 |
Pyridine |
5.0 |
|
D016 |
2,4-D |
10.0 |
D039 |
Tetrachloroethylene |
0.7 |
|
D027 |
1,4-Dichlorobenzene |
7.5 |
D015 |
Toxaphene |
0.5 |
|
D028 |
1,2-Dichloroethane |
0.5 |
D017 |
2,4,5-TP Silvex |
1.0 |
|
D029 |
1,1-Dichloroethylene |
0.7 |
D040 |
Trichloroethylene |
0.5 |
|
D030 |
2,4-Dinitrotoluene |
0.13 |
D041 |
2,4,5-Trichlorophenol |
400.0 |
|
D012 |
Endrin |
0.02 |
D042 |
2,4,6-Trichlorophenol |
2.0 |
|
D031 |
Heptachlor |
0.008 |
D043 |
Vinyl chloride |
0.2 |
3. What is a listed Hazardous waste?
Unused or unopened chemicals will meet the definition of a listed hazardous waste if they appear on one of two EPA lists. The U-list contains materials that are hazardous and the P-list contains materials that are acutely hazardous. These lists only apply to unused materials that have one of the listed chemicals as the sole active ingredients. The list also applies to spill cleanups of these unused materials. The complete U-list and P-list are can be found on the EHRS website.
Additionally, certain used or spent solvents can be regulated as a hazardous waste if they appear on the F-list which can be found on the EPA website
Empty containers that previously contained a P-listed chemical such as sodium azide or cyanide salts are also regulated as a hazardous waste. These containers must be labeled with a hazardous waste label and given to EHRS for disposal. Most other empty containers can be triple rinsed and discarded in the regular trash.