Some hazardous wastes are more hazardous than others.
The RCRA hazardous waste management standards regulate “acute” hazardous wastes more stringently than wastes that are only ignitable, corrosive, reactive, or toxic. But what is an acute hazardous waste, and what does it mean for your facility if you generate one or more of them?
First, an acute hazardous waste is a waste shown to be fatal to humans in low doses.
In the absence of test data on human toxicity, the following criteria are used to designate a waste as acutely hazardous:
- An oral LD50 toxicity (rat) of less than 50 milligrams per kilogram,
- An inhalation LC50 toxicity (rat) of less than 2 milligrams per liter, or
- A dermal LD50 toxicity (rabbit) of less than 200 milligrams per kilogram or is otherwise capable of causing or significantly contributing to an increase in serious irreversible, or incapacitating reversible, illness.
These criteria are spelled out in the regulations at 40 CFR 261.11(a)(2).
Listed Acute Hazardous Waste
It’s easy to spot acute hazardous wastes in the RCRA regulations. All discarded, unused commercial chemical products on the P-list at §261.33(e)–and mixtures or formulations containing the chemical as a sole active ingredient–are acute hazardous wastes.
Used or spent process wastes on the F-list at 40 CFR 261.31 and identified with a hazard code "H" are also acute hazardous wastes.
How Acute Hazardous Waste Affect RCRA Compliance
Not only is it important for employee safety for workers to know that the chemical they’re handling is acutely hazardous— it also impacts hazardous waste compliance in some major ways.
Your Site’s RCRA Generator Status.
Generators must count acute hazardous waste separately from non-acute hazardous waste. If your site generates greater than 1 kg
of acute hazardous waste in a calendar month, then the whole site is a large quantity generator (LQG) and must comply with the requirements for LQGs in 40 CFR 262.17.
The LQG exemption has the most stringent rules for RCRA training
, reporting, contingency plans, onsite accumulation, and more.
In addition, just accumulating
more than 1 kg of acute hazardous waste onsite at any one time can have repercussions. The very small quantity generator would have to manage their acute hazardous waste according to the LQG exemption. (See 40 CFR 262.14(a)(3)).
Satellite areas accumulation.
According to the satellite rules for large and small quantity generators at 40 CFR 262.15, a generator may accumulate up to 1 kg of physically solid acute hazardous waste or 1 quart of liquid acute hazardous waste at or near the initial point of generation without triggering additional management requirements. This is in contrast to the 55 gallon threshold for non-acute hazardous waste.
Understanding the distinction between acute hazardous waste and non-acute hazardous waste is essential to accurately determine your RCRA generator category and properly manage your site's hazardous waste.. Generating or accumulating even small amounts of these wastes can subject your facility to more stringent management requirements.
In-person RCRA Training Returns in 2021!
Develop in-depth expertise to simplify compliance with the RCRA regulations! Keep your expertise sharp and network with your peers when Lion presents the two-day RCRA Hazardous Waste Management Workshop
, St. Louis
, and Cincinnati
in August and September 2021.
Save your seat now to help meet EPA's annual training mandate for hazardous waste personnel (40 CFR 262.17).
Can’t join us live?
Train online at your own pace, or join us for a live, instructor-led webinar. Visit Lion.com/RCRA
to see all your options and help satisfy EPA’s annual training mandate for hazardous waste personnel