Lion.com will be offline for scheduled maintenance from 11 PM ET on Saturday, September 13, to 1 AM ET on Sunday, September 14.
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 chose Lion's online webinar because it is simple, effective, and easily accessible.

Jeremy Bost

Environmental Health & Safety Technician

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

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

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

Amazing instructor; real-life examples. Lion training gets better every year!

Frank Papandrea

Environmental Manager

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

Download Our Latest Whitepaper

What to do before, during, and after a RCRA hazardous waste inspection to defend your site from rising State and Federal penalties.

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.