Search

RCRA and Heavy Metals: The Toxicity Characteristic

Posted on 7/31/2019 by Roseanne Bottone and Roger Marks

When I hear poison and heavy metal in the same sentence, my mind first goes to the 80’s rockers who recorded the #1 hit “Every Rose Has Its Thorn.” Second, though, I think of the RCRA toxicity characteristic.

Music fans might argue about whether Poison’s songs should be called heavy metal, glam metal, hair metal, or something else. But when it comes to the eight naturally occurring elements called heavy metals, the answer is much more scientific: A metal is a heavy metal if its atomic weight or density is greater than or equal to five times that of water.

The RCRA toxicity characteristic described at 40 CFR 261.24 covers eight heavy metals. Sometimes referred to as the “RCRA 8 Metals,” they are:
  • Arsenic (Waste code: D004)
  • Barium (D005)
  • Cadmium (D006)
  • Chromium (D007)
  • Lead (D008)
  • Mercury (D009)
  • Selenium (D010)
  • Silver (D011)
These metals have wide applications in many industrial, medical and technological processes, and their toxicity poses a threat to human health and the environment. As systemic toxicants that can cause organ damage even at low doses, they have been classified as known or probable human carcinogens by the EPA.

Environmental contamination and human exposure can result from mining and smelting activities; industrial operations such as metal processing, coal burning, petroleum combustion, and nuclear power generation; the production of plastics, textiles, microelectronics; and in the wood preservation and paper processing industries.

Measuring Toxicity: The TCLP Test

To determine whether it meets the definition of a hazardous waste for land disposal purposes, the Toxic Characteristic Leaching Procedure (TCLP) test is typically needed. The TCLP test simulates how much of a toxic constituent will “leach out” of the waste after it is disposed of.

All eight heavy metals have a corresponding allowable limit under the RCRA regulations, ranging from 0.2 mg/L (for mercury) to 100 mg/L (barium). If the concentration of the toxic constituent in your waste is above this limit, the waste must be disposed of as a hazardous waste.

To see the regulatory levels for all toxic heavy metals—and the other substances covered under the toxicity characteristic—refer to Table 1 at 40 CFR 261.24.

Get RCRA Trained—When You Want, Where You Want

hazardous waste storageUS EPA requires hazardous waste professionals to complete annual training on the RCRA requirements. Lion makes it easy to meet your RCRA training mandate in a variety of formats—nationwide public workshops, convenient online courses, live webinars, and on-site training.

Browse RCRA training options here to find the course that fits your needs, your schedule, and your learning style.

Want live training? Join us for the RCRA Hazardous Waste Management Workshop near you next month:

Tulsa, OK Aug. 1–2
New Orleans, LA Aug. 1–2
Houston, TX Aug. 5–6
San Antonio, TX Aug. 14–15
Seattle, WA Aug. 15–16
Dallas, TX Aug. 19–20
Las Vegas, NV Aug. 19–20
Phoenix, AZ Aug. 22–23
Minneapolis, MN Sept. 9–10
Cedar Rapids, IA Sept. 12–13
Chicago, IL Sept. 16–17

Tags: hazardous waste management, RCRA, RCRA metals

Find a Post

Compliance Archives

Lion - Quotes

Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!

Oscar Fisher

EHS Manager

This is the best RCRA training I've experienced! I will be visiting Lion training again.

Cynthia L. Logsdon

Principal Environmental Engineer

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

Download Our Latest Whitepaper

Four key considerations to help you maximize the convenience and quality of your experience with online training.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.