How to Identify Solid Waste

If your business or organization uses or creates chemicals or oils, cleaning solvents, aerosols, batteries, electronics and so on, how do you know when it goes from a product you can use to a waste that you potentially need to store, track, and dispose of according to specific regulations?

The Solid Waste Umbrella

When we talk about waste in the context of RCRA, the word refers to an enormous range of waste that US EPA calls “solid waste.” Understanding what is or is not a solid waste is hugely important because solid waste is an umbrella term in the regulations, and all hazardous waste falls under that umbrella.

If we want to know if something is a hazardous waste, we first need to know if it is a solid waste. It also means that if a material is not a solid waste, then it is not a hazardous waste either, according to the RCRA regulations.

Is a solid waste always solid?

Don’t be misled by its name. A solid waste can be a solid, liquid, a semisolid, or even a gas.

“any garbage, refuse, sludge… and other discarded material, including solid, liquid semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities…”
[42 USC $6903(27)]

The 4 Solid Waste Criteria

A material is a solid waste when it is:

1. Abandoned
   • Dispose, burned/incinerated, stored before disposal or incineration
2. Recycled in certain ways
   • Varies based on type of material, its properties, and the method of recycling.
   • A material may be a solid waste if you burn it as fuel, but might not be a solid waste if you distill it to recover some product that you can re-use.
3. “Inherently waste like”
   • Includes certain toxic byproducts from specific industrial processes.
4. A military munition (40 CFR 266.202)
   • Example: when a military munition is a solid waste when it is “deteriorated or damaged to the point that it cannot be put into serviceable condition and cannot reasonably be recycled or used for other purposes.” [40 CFR 266.202(b)]

The First Step in Hazardous Waste ID

Remember how we said that a solid waste is an umbrella term, and all hazardous waste falls under that umbrella? Well, now that we know how to identify a solid waste, we’re passed the first hurdle in determining if a material is a hazardous waste.

If we’ve determined the material is a solid waste, we can examine it further to determine if it meets any of the RCRA criteria for regulation as a hazardous waste based on things like its physical and chemical properties, any hazards it presents, or what industry sector or specific process it came from.

On the other hand, if our material is not a solid waste, we’re done with waste ID, and we’re grateful that we don’t have to dive further into complicated government regulations.

Everyone else should consider Lion’s RCRA Hazardous Waste Management training.

Tags: EPA, hazardous waste management, RCRA