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.

Stay Up to Date on the Latest Rules

Subscribe to Lion News for more breaking regulatory news, exclusive content on hazardous waste (RCRA), hazmat shipping (49 CFR), and other industry topics that affect your job—delivered directly to your inbox. Customize your subscription to receive only the news and regulatory guidance that affect you. 


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. 

Tags: hazardous waste, RCRA

Find a Post

Compliance Archives

Lion - Quotes

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

Rebecca Saxena

Corporate Product Stewardship Specialist

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

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

Gregory Thompson

Environmental, Health & Safety Regional Manager

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

Marc Bugg

Hazardous Waste Professional

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

Brody Saleen

Registered Environmental Health Specialist

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

Johnny Barton

Logistics Coordinator

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

Gary Hartzell

Warehouse Supervisor

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 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

Download Our Latest Whitepaper

In most cases, injuries that occur at work are work-related and must be recorded to maintain compliance with OSHA regulations. This report shows you the 9 types of injuries you don’t record.

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.