Lion News May 2016

News / May 2016 / RCRA Hazardous Waste ID in 3 Steps: Trichloroethylene
Find a Course

RCRA Hazardous Waste ID in 3 Steps: Trichloroethylene

Posted on May 24, 2016 by Roseanne Bottone

In order to dispose of any RCRA hazardous waste, generators must assign the proper “waste codes.” RCRA wastes codes are alphanumeric indicators that provide specific information about how a waste should be treated to make it safe for disposal. Assigning waste codes is a complex—and absolutely crucial—part of managing hazardous waste.

If you choose the wrong waste codes, your waste may not be treated properly—leading to environmental contamination, EPA civil penalties, liability for cleanup under CERCLA/Superfund, and even negative media attention. For more on the different kinds of RCRA waste codes and when they apply, read Simplify Your Approach to Waste ID.

What Is Trichloroethylene?


Trichloroethylene, or TCE, is a commonly used chemical in US industry. It serves a variety of cleaning, degreasing, and other purposes. When disposed of, TCE is regulated by US EPA as a hazardous waste. Like any other hazardous waste, TCE needs proper waste codes before it can be sent off for disposal. But what RCRA hazardous waste codes are applicable to this material?

We can determine which waste codes to use using 3 simple steps to waste ID. Let’s get started!

RCRA hazardous waste identification


The 3 Steps to Hazardous Waste ID


  1. Gather physical and chemical data about the material.
  2. Determine or consider how the waste was generated.
  3. Perform the waste ID process in the RCRA regulations at 40 CFR 262.11.

Step 1: Gather Data About the Hazardous Waste


To properly identify any hazardous waste, you need information about its physical state and chemical properties. Whenever possible, generators should consult more than one source of data to make sure the information is accurate and complete. Places you might look for information about your hazardous waste include:

  • Safety Data Sheets (SDSs)
  • Chemical Books
  • Online searches
  • Manufacturers’ specification information
  • Laboratory analyses
  • Industry/Generator knowledge
For trichloroethylene, we’ve compiled some information from several manufacturers’ Safety Data Sheets.

Physical properties: Clear Liquid, sweet odor
Flash point: Not available (non-flammable)
pH: Not available
Chemical stability: Stable under normal ambient and anticipated storage and handling conditions of temperature and pressure.
Caution: Swallowing can result in nausea, vomiting, and central nervous system depression.

Step 2: How Did We Generate the Hazardous Waste?


Another factor that affects the assignment of applicable RCRA waste codes is how the material was used. (Note: If a material is disposed of before it’s used, our approach will be a bit different, and we’ll discuss this as part of Step 3.)

Approximately 80% of trichloroethylene is used as a solvent for vapor degreasing of fabricated metal parts and textiles. Another 5% is used as an ingredient to produce organic chemicals and pharmaceuticals. The remainder of the TCE is used as a solvent for dry cleaning and as a refrigerant/heat exchange liquid.

How our TCE was used—or not used, for that matter—will inform how we select waste codes in the next and final step.

Step 3: Follow the Hazardous Waste Determination Method Specified at 40 CFR 262.11


To know what type of hazardous waste we have and apply the right codes, we first must determine if our material is in fact a hazardous waste at all. At 40 CFR 261.4, EPA provides exclusions from the definition of solid/hazardous waste. There are no exclusions specifically for the management of waste TCE.

Next, we must see if our waste exhibits a hazardous waste characteristic described at 40 CFR 261, Subpart C or appears on a list in 40 CFR 261, Subpart D. From a practical perspective, you may do this in either order—but you must do both. Let’s start with the characteristics.

The four RCRA hazardous waste characteristics and the general criteria for each are as follows:

Waste Code Characteristic Generally based on… 40 CFR Reference
D001 Ignitability Flash point §261.21
D002 Corrosivity pH and corrosion of steel §261.22
D003 Reactivity Stability §261.23
D004–D043 Toxicity Certain levels of 40 specific contaminants §261.24

Since TCE does not meet the flash point or pH criteria for ignitability and corrosivity, respectively, and it is stable, it is not a D001, D002, or D003 hazardous waste. Trichloroethylene is, however, one of the toxicity characteristic contaminants and, if our waste contains greater than 0.5 mg/L TCE, it would carry the D040 waste code.

Next, let’s determine if our waste is described on a list. This is where it becomes important to know how the waste was generated.

Process Waste


If the TCE is “used” or “spent” (i.e., it has gone through some sort of process), we will look at the F codes at 40 CFR 261.31 or the K codes at 40 CFR 262.32. Trichloroethylene is listed in two places on the F List and we would look here only if our TCE was used for its solvent properties.


Unused Commercial Chemical Product

  • If the TCE was used for its solvent properties in a degreasing process, we would assign it the F001 waste code.
  • If the TCE was used for its solvent properties in a process other than degreasing (e.g., dry cleaning), it would carry the F002 waste code.
  • If the TCE was used in a process, but not for its solvent properties (e.g., as a heat exchange fluid), it would not be assigned an F code.

Suppose we are disposing of unused TCE. Perhaps it expired, or it is off-spec, or we no longer have a use for it. Once we decide to dispose of it, we would then look at the P and U codes at 40 CFR 261.33.

P codes apply to commercial chemical products that are acutely hazardous. [40 CFR 261.33(e)] U codes apply to unused products with sole active ingredients, off-spec batches of such products, and residues from storage or cleanup of spills of such products. [40 CFR 261.33(f)] Unused trichloroethylene is listed as a U228.

Lastly, we give our waste all applicable waste codes and keep a detailed waste profile record to substantiate our decisions.

No matter what type(s) of hazardous waste you generate or come across at your site, use the simple three-step process above to identify the waste and make accurate determinations. Assigning the proper waste codes is critical to protect the environment from contamination and shield your business from civil penalties and future liability.  

RCRA Training for New and Experienced Pros


Be confident you know what it takes to keep your site in compliance with the latest US EPA RCRA hazardous waste rules for large, small, and conditionally exempt (very small) generators! Don’t miss the hazardous waste training trusted by professionals nationwide when the Hazardous/Toxic Waste Management Workshop comes through your area!

Need to know more about the RCRA hazardous waste ID rules? The new, interactive Land Disposal Restrictions Online Course guides you through a simple five-step process for meeting the LDRs when the time comes to dispose of your site’s hazardous waste. Sign up now and get six months of Lion Membership for fast answers to your questions, rule updates, exclusive content, discounts on select webinars, and much more!
Lion - Quotes

"The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!"

Curtis Ahonen

EHS&S Manager

"These are the best classes I attend each year. I always take something away and implement improvements at my sites."

Kim Racine

EH&S Manager

"Lion is easily and consistently the best option for compliance training. I've learned new information from every instructor I've had."

Rachel Mathis

EHS Specialist

"Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat. "

Genell Drake

Outbound Lead

"I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!"

Sara Sills

Environmental Specialist

"The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing."

Linda Arlen

Safety & Environmental Compliance Officer

"As always, Lion never disappoints"

Paul Resley

Environmental Coordinator

"I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for."

Frank Sizemore

Director of Regulatory Affairs

"I was recently offered an opportunity to take my training through another company, but I politely declined. I only attend Lion Technology workshops."

Stephanie Gilliam

Material Production/Logistics Manager

"Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider."

Francisco Gallardo

HES Technician

"The instructor was excellent. They knew all of the material without having to read from a notepad or computer. "

Gary Hartzell

Warehouse Supervisor

"I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down."

Nicole Eby

Environmental Specialist

"This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions."

Amanda Oswald

Shipping Professional

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

Cynthia L. Logsdon

Principal Environmental Engineer

"I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!"

Henry Watkins

Hazardous Waste Technician

"I can't say enough how pleased I was with this course! Everything finally makes sense."

Kim Graham

Lab Manager

"The instructor was energetic and made learning fun compared to dry instructors from other training providers."

Andy D’Amato

International Trade Compliance Manager

"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

"I have been to other training companies, but Lion’s material is much better and easier to understand."

Mark Abell

Regional Manager

"I love that the instructor emphasized the thought process behind the regs."

Rebecca Saxena

Corporate Product Stewardship Specialist

"More thorough than a class I attended last year through another company."

Troy Yonkers

HSES Representative

"Amazing instructor; real-life examples. Lion training gets better every year!"

Frank Papandrea

Environmental Manager

"The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun."

Teresa Arellanes

EHS Manager

"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

"The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable."

Mary Sue Michon

Environmental Administrator

"The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly."

Brittany Holm

Lab Supervisor

"These are the best commercial course references I have seen (10+ years). Great job!"

Ed Grzybowski

EHS & Facility Engineer

"Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms."

David Hertvik

Vice President

"You blew the doors off the competition!"

Stephen Bieschke

Facilities Manager

"I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop."

Tom Bush, Jr.

EHS Manager

"Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are."

Amanda Schwartz

Environmental Coordinator

"The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information."

Stephanie Venn

Inventory Control Specialist

"Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic."

Dorothy Rurak

Environmental Specialist

"If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials."

Bryce Parker

EHS Manager

"I appreciate the focus on what the regulations tell us to do, as well as what is subject to interpretation."

Nicole Eby

Environmental Specialist

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

Morgan Bliss

Principal Industrial Hygienist

"Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right."

Gregory Thompson

Environmental, Health & Safety Regional Manager

"I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better."

Danny Province

EHS Professional

"Content was comprehensive and seemed to really “dig in” to the material. I liked the option to review FAQs and re-review the quiz questions."

Morgan Bliss

Principal Industrial Hygienist

"The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete."

Felicia Rutledge

Hazmat Shipping Professional

"The course is well thought out and organized in a way that leads to a clearer understanding of the total training."

David Baily

Hazmat Shipping Professional

"This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things. "

Quatama Jackson

Waste Management Professional

"The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others."

Donnie James

Quality Manager

"My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material."

Robert Roose

Manager, Dangerous Goods Transportation

"Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs."

Neil Luciano

EHS Manager

"The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course."

Jeffrey Tierno

Hazmat Shipping Professional

"Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training."

Caroline Froning

Plant Chemist

"The course was very well structured and covered the material in a clear, concise manner."

Ian Martinez

Hazmat Shipping Professional

"The online course was well thought out and organized, with good interaction between the student and the course."

Larry Ybarra

Material Release Agent

"My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow."

Steven Erlandson

Environmental Coordinator

"I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective."

John Gratacos

Logistics Manager

"Lion does a great job summarizing and communicating complicated EH&S-related regulations."

Michele Irmen

Sr. Environmental Engineer

"Far superior in terms of detail and instructional/support materials. The depth of instructor knowledge is always beyond any other training I have participated in."

Linda Arlen

Safety & Environmental Compliance Officer

"The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked. "

Johnny Barton

Logistics Coordinator

"I have returned to Lion's compliance training for several years and prefer to stay with a trusted source. The material and presentation are far superior than others I have taken."

Robert Roose

Manager, Dangerous Goods Transportation

"I chose Lion's online webinar because it is simple, effective, and easily accessible. "

Jeremy Bost

Environmental Health & Safety Technician

"Lion's information is very thorough and accurate. Presenter was very good."

Melissa Little

Regulatory Manager

"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

"The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!"

Brian Martinez

Warehouse Operator

"Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again."

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

"I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities."

Pamela Embody

EHS Specialist

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

Amanda Walsh

Hazardous Waste Professional

"Lion was very responsive to my initial questions and the website was user friendly."

Michael Britt

Supply Chain Director

"Convenient; I can train when I want, where I want."

Barry Cook

Hazmat Shipping Professional

"Having the tutorial buttons for additional information was extremely beneficial."

Sharon Ziemek

EHS Manager

"We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training."

Timothy Mertes

Hazmat Shipping Professional

"Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented."

George Bersik

Hazardous Waste Professional

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

Brody Saleen

Registered Environmental Health Specialist

"Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well."

Marty Brownfield

Hazardous Waste Professional

"The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!"

Chelsea Minguela

Hazmat Shipping Professional

"Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time."

Kimberly Arnao

Senior Director of EH&S

"Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers."

Robert Brenner

District Environmental Manager

"I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!"

Diana Joyner

Senior Environmental Engineer

"The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers."

George Alva

Manufacturing Manager

"The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable."

Marc Bugg

Hazardous Waste Professional

"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

"Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed."

John Hutchinson

Senior EHS Engineer

"The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again."

John Nekoloff

Environmental Compliance Manager

"The instructor was very engaging and helped less experienced people understand the concepts."

Steve Gall

Safety Leader

"This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!"

Lori Hardy

Process & Resource Administrator

"I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past."

Neil Ozonur

Safety Officer

"The instructor created a great learning environment."

Avinash Thummadi

CAD & Environmental Manager

"Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!"

Paul Harbison

Hazardous Waste Professional

"The instructor took a rather drab set of topics and brought them to life with realistic real-life examples."

Tom Berndt

HSE Coordinator

"Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything."

Ellen Pelton

Chemical Laboratory Manager

"I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!"

George Chatman

Hazardous Material Pharmacy Technician

"I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!"

Kevin Pylka

Permitting, Compliance & Environmental Manager

"No comparison. Lion has the best RCRA training ever!!"

Matt Sabine

Environmental Specialist

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

John Troy

Environmental Specialist

"The instructor was very very informative, helpful, understandable and pleasant. This course answered many questions I had, being new to this industry."

Frances Mona

Shipping Manager

"I will never go anywhere, but to Lion Technology."

Dawn Swofford

EHS Technician

"Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!"

Stephanie Weathers

SHE Specialist

"One of the best trainings I have ever received!"

Brandon Morfin

EH&S Manager

"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 was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years! "

Tony Petrik

Hazmat Shipping Professional

"The instructor made the class very enjoyable and catered to the needs of our group."

Sarah Baker

Planner

"The instructor was very patient and engaging - willing to answer and help explain subject matter."

Misty Filipp

Material Control Superintendent

"Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!"

Marti Severs

Enterprise Safety Manager

"Lion is my preferred trainer for hazmat and DOT."

Jim Jani

Environmental Coordinator

download our latest whitepaper

This report answers two common questions concerning the hazardous waste manifest: "Is training required for person who sign the manifest?" and "If so, what training is required?"

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 Current and Privacy Policy.

Training Employees to Sign the Manifest