EPA May Expand RCRA Classification of Corrosives

Posted on 4/13/2015 by Roger Marks

US EPA is now under pressure to respond to a lawsuit challenging the Agency’s standard for characterizing corrosive hazardous wastes under the Resource Conservation and Recovery Act (RCRA) regulations. The lawsuit, filed three years ago by the Public Employees for Environmental Responsibility (PEER), asserts that US EPA based its RCRA corrosivity standard on poorly chosen criteria when the regulations were originally written in the early 1980s.1  

The PEER lawsuit requests two major changes to the current RCRA standard that would broaden the scope of materials that are characterized as corrosive hazardous waste. This major shift has the potential to bring new facilities and materials under the purview of the US EPA hazardous waste enforcement program. 

Under a motion reached last week, US EPA will address the changes by March 31, 2016, by either proposing new rules or officially declining to do so via the Federal Register. 1
PH Meter for Corrosive RCRA Waste

What Is Corrosivity?

As defined in RCRA, corrosivity is a measure of how quickly and severely an aqueous (liquid) material will destroy human skin. Exposure to corrosive waste can cause skin damage, including chemical burns, hardening of tissue, and even complete destruction.2 Corrosivity is measured two ways under RCRA:

1.       By a material’s pH (extreme high or low), or
2.       By the rate at which the material melts steel.3

Major RCRA Change #1 – Lowering the Basic (Alkali) Threshold

To be characterized as a corrosive waste under EPA’s current RCRA rules, a waste must be aqueous (liquid) and have a pH of 2 or lower (very acidic) or 12.5 or higher (very basic/alkali). As a point of reference, the pH of pure water is 7. The PEER lawsuit points to World Health Organization guidance which, per the claim against EPA, illustrates the need for a tightened “basic” pH standard of 11.5.1  
To those not acquainted with the science, a decrease of 1.0 may seem insignificant. In fact, the pH scale is logarithmic, meaning that for every 1.0 rise in pH, the destructive potential rises by ten times. In other words, a substance with a pH of 12.5 is actually ten times as harmful as an 11.5 pH substance. According to the North Carolina Department of Health, “With respect to the severity of chemical burns from acids and alkalis, burns from alkalis tend to be the more severe.”2

Major RCRA Change #2 – Expanding the Definition of Corrosives to Include Solids

The current RCRA regulations require a substance to be aqueous (liquid) to be characterized as corrosive. The PEER lawsuit addresses the fact that certain solids, when wetted, can shed corrosive liquid that is just as harmful to workers.
Several US states already include criteria for corrosive solids in their State hazardous waste rules. The PEER lawsuit requests that EPA adopt criteria for identifying solids that may create or shed a corrosive liquid when wet.  

What It Means for RCRA Professionals

If EPA opts to propose new rules in line with requests in the lawsuit, a lowered basic (or alkali) pH standard of 11.5 would broaden the scope of materials that meet the corrosive criteria. Ammonia, major constituent in pharmaceuticals and commercial cleaning products, has a pH of about 11.6. As a material with a pH above 11.5, ammonia would then be characterized as corrosive waste and subjected to the full scope of RCRA regulations governing its handling, storage, marking and labeling, and disposal.

If US EPA adopts criteria for characterizing solids as corrosive, which US DOT and many State agencies already do, it would expand the universe of materials that would be subject to the RCRA hazardous waste regulations.

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1.       EPA Agrees To 2016 Deadline For Decision On RCRA Corrosivity Standard. Inside EPA’s Superfund Report, Vol. XXIX, No. 7, pp. 14-15. March 30, 2015.
2.       A Guide to Working with Corrosive Substances. N.C. Dept. of Labor, Occupational Safety and Health Division. Cherie Berry, Commissioner of Labor. November 2013.
3.       Hazardous Waste Management Compliance Reference, pp. 46-47. Lion Technology, 2015. 

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