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:

Tulsa, OK Aug. 1–2
New Orleans, LA Aug. 1–2
Houston, TX Aug. 5–6
San Antonio, TX Aug. 14–15
Seattle, WA Aug. 15–16
Dallas, TX Aug. 19–20
Las Vegas, NV Aug. 19–20
Phoenix, AZ Aug. 22–23
Minneapolis, MN Sept. 9–10
Cedar Rapids, IA Sept. 12–13
Chicago, IL Sept. 16–17

Tags: hazardous waste management, RCRA, RCRA metals

Find a Post

Compliance Archives

Lion - Quotes

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.

Teresa Arellanes

EHS Manager

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

I love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

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

David Hertvik

Vice President

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

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

Mark Abell

Regional Manager

Lion is my preferred trainer for hazmat and DOT.

Jim Jani

Environmental Coordinator

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

Download Our Latest Whitepaper

Tips to identify and manage universal waste under more-stringent state regulations for generators and universal waste handlers in California.

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.