Search

Are All D001 Wastes Flammable Hazardous Materials?

Posted on 2/25/2020 by Flip De Rea

Flip is an instructfor for Lion's Multimodal Hazmat Shipper Certification Workshops. Join LIon in Houston, Los Angeles, Denver, Las Vegas, Kansas City, Chicago, and St. Louis for reliable, up to date 49 CFR, IATA DGR, and IMDG Code training in Spring 2020. Save your seat today.

Ignitable and flammable are words that sound interchangeable; and may used as synonyms in casual conversation. But if you manage hazardous waste or ship hazardous materials, you know that ignitable and flammable each have distinct regulatory definitions, and both terms should raise a red flag for you.

Wastes identified by the Environmental Protection agency (EPA) as Ignitable hazardous wastes are assigned a D001 waste code and must be managed as hazardous waste on site, according to your RCRA generator status. Materials identified by the Department of Transportation (DOT) as Flammable require specific preparation and handling when moved from location to location.

Often, Ignitable wastes are flammable materials. Sometimes, though, they're not..

The Resource Conservation and Recovery Act (RCRA) identifies four ways that a waste might be assigned the Characteristic of Ignitability. Each different way will match up with at least one DOT regulated hazard class, but not necessarily the same DOT hazard class each time. Let’s look at the possibilities.

Ignitable Liquids 

The first RCRA description of an Ignitable waste is a liquid with a “flash point less than 60 °C (140 °F)”. If you’ve assigned a D001 waste code to your waste for that reason, then, when it comes to transport, your waste will meet the definition of DOT hazard class 3, Flammable Liquids; a liquid having a flash point of not more than 60 °C (140 °F).

Ignitable Non-liquids 

RCRA also describes Ignitable wastes as wastes that are “not a liquid” and are “capable of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard”.

If you’ve assigned a D001 waste code to your waste for one of those reasons, then, when it comes to transport, your waste will likely meet one of the definitions of DOT hazard class 4.

Hazard Class 4 is split into three divisions.

Division 4.1 refers to “flammable solids”. (capable of causing fire through friction)

Division 4.2 is for “spontaneously combustible materials”. (capable of causing fire through spontaneous chemical changes) 

Division 4.3 is for materials that are “dangerous when wet”. (capable of causing fire through absorption of moisture)

Further analysis would be required to establish your non-liquid waste's exact characteristics to properly classify it for transportation under 49 CFR hazmat regulations.

Ignitable Compressed Gases 

RCRA also describes Ignitable wastes as wastes that are “an ignitable compressed gas”. If you’ve assigned a D001 waste code to your waste for that reason, then, when it comes to transport, your waste will likely meet the definition of DOT division 2.1, Flammable Gas. In this case the EPA and the DOT have similar, but distinct, definitions of “compressed gas” and some legwork would be required.

Ignitable Oxidizers 

RCRA also describes Ignitable wastes as wastes that are “an oxidizer”. If you’ve assigned a D001 waste code to your waste for that reason, then, when it comes to transport, your waste will likely meet the definition of DOT division 5.1, oxidizers. Here again, US EPA and US DOT maintain different (but similar) definitions of “oxidizer” and some ground-truthing would be required.

While the words ignitable and flammable largely mean the same thing, understanding the subtle differences and proper uses of these two terms is critical to avoid noncompliance with RCRA and 49 CFR hazmat regulations.  

Multimodal Hazmat Shipper Training (49 CFR, IATA, IMDG)

Develop the in-depth expertise you need to ship hazardous materials by ground, air, and vessel, in full compliance with the latest US and international requirements.

The Complete Multimodal Hazmat Shipper Certification Workshops cover the 49 CFR (US DOT), IATA DGR, and IMDG Code regulations that govern the domestic and international transport of hazardous materials.

Tags: Classifying hazmat, hazardous materials regulations, hazardous waste management, hazmat shipping, RCRA

Find a Post

Compliance Archives

Lion - Quotes

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

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

David Hertvik

Vice President

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

Troy Yonkers

HSES Representative

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

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 engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

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

Michael Britt

Supply Chain Director

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

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

Barry Cook

Hazmat Shipping Professional

Download Our Latest Whitepaper

Look beyond the annual "Top 10 List" to see specifics about the most cited OSHA health & safety Standards and the individual regulations that tripped up employers the most last year. 

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.