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RCRA and Heavy Metals: The Toxicity Characteristic

Posted on 7/31/2019 by Roseanne Bottone and Roger Marks

When I hear poison and heavy metal in the same sentence, my mind first goes to the 80’s rockers who recorded the #1 hit “Every Rose Has Its Thorn.” Second, though, I think of the RCRA toxicity characteristic.

Music fans might argue about whether Poison’s songs should be called heavy metal, glam metal, hair metal, or something else. But when it comes to the eight naturally occurring elements called heavy metals, the answer is much more scientific: A metal is a heavy metal if its atomic weight or density is greater than or equal to five times that of water.

The RCRA toxicity characteristic described at 40 CFR 261.24 covers eight heavy metals. Sometimes referred to as the “RCRA 8 Metals,” they are:
  • Arsenic (Waste code: D004)
  • Barium (D005)
  • Cadmium (D006)
  • Chromium (D007)
  • Lead (D008)
  • Mercury (D009)
  • Selenium (D010)
  • Silver (D011)
These metals have wide applications in many industrial, medical and technological processes, and their toxicity poses a threat to human health and the environment. As systemic toxicants that can cause organ damage even at low doses, they have been classified as known or probable human carcinogens by the EPA.

Environmental contamination and human exposure can result from mining and smelting activities; industrial operations such as metal processing, coal burning, petroleum combustion, and nuclear power generation; the production of plastics, textiles, microelectronics; and in the wood preservation and paper processing industries.

Measuring Toxicity: The TCLP Test

To determine whether it meets the definition of a hazardous waste for land disposal purposes, the Toxic Characteristic Leaching Procedure (TCLP) test is typically needed. The TCLP test simulates how much of a toxic constituent will “leach out” of the waste after it is disposed of.

All eight heavy metals have a corresponding allowable limit under the RCRA regulations, ranging from 0.2 mg/L (for mercury) to 100 mg/L (barium). If the concentration of the toxic constituent in your waste is above this limit, the waste must be disposed of as a hazardous waste.

To see the regulatory levels for all toxic heavy metals—and the other substances covered under the toxicity characteristic—refer to Table 1 at 40 CFR 261.24.

Get RCRA Trained—When You Want, Where You Want

hazardous waste storageUS EPA requires hazardous waste professionals to complete annual training on the RCRA requirements. Lion makes it easy to meet your RCRA training mandate in a variety of formats—nationwide public workshops, convenient online courses, live webinars, and on-site training.

Browse RCRA training options here to find the course that fits your needs, your schedule, and your learning style.

Want live training? Join us for the RCRA Hazardous Waste Management Workshop near you next month:

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Phoenix, AZ Aug. 22–23
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Chicago, IL Sept. 16–17

Tags: hazardous waste management, RCRA, RCRA metals

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