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

I have been to other training companies, but Lion’s material is much better and easier to understand.

Mark Abell

Regional Manager

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information.

Stephanie Venn

Inventory Control Specialist

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs.

Neil Luciano

EHS Manager

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

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

Brody Saleen

Registered Environmental Health Specialist

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

Download Our Latest Whitepaper

Knowing why TSDFs reject loads of hazardous waste—and the exact steps to follow if it happens—can reduce your anxiety and uncertainty about rejection.

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.