What Is an Acute Hazardous Waste?
Most hazardous wastes covered by the RCRA generator regulations are regulated because they are ignitable, corrosive, reactive, and/or toxic. Some regulated wastes, called acute hazardous wastes, are regulated more stringently because they are known to be fatal to humans in low doses.
Because of the danger they pose, acute hazardous wastes are subject substantial restrictions and disposal requirements under RCRA. If your site generates any type of hazardous waste, it is crucial to recognize when one or more of your waste streams is designated as an acutely hazardous.
In addition, accumulating more than 1 kg of acute hazardous waste onsite at any one time can have repercussions. A small or very small quantity generator would have to manage their acute hazardous waste according to the LQG exemption. (See 40 CFR 262.14(a)(3)).
Note: A 1 kg accumulation limit for acute hazardous waste for SQGs is effective as of March 21, 2025.
Understanding the distinction between acute hazardous waste and non-acute hazardous waste is essential to accurately determine your RCRA generator category and properly manage your site's hazardous waste. Generating or accumulating even small amounts of these wastes can subject your facility to more stringent management requirements.
Because of the danger they pose, acute hazardous wastes are subject substantial restrictions and disposal requirements under RCRA. If your site generates any type of hazardous waste, it is crucial to recognize when one or more of your waste streams is designated as an acutely hazardous.
How to Identify Acute Hazardous Waste
In the absence of test data on human toxicity, the criteria for designating a waste as acutely hazardous are found in the regulations at 40 CFR 261.11(a)(2):- An oral LD50 toxicity (rat) of less than 50 milligrams per kilogram,
- An inhalation LC50 toxicity (rat) of less than 2 milligrams per liter, or
- A dermal LD50 toxicity (rabbit) of less than 200 milligrams per kilogram or is otherwise capable of causing or significantly contributing to an increase in serious irreversible, or incapacitating reversible, illness.
Listed Acute Hazardous Waste
Some listed hazardous wastes are identified as acutely hazardous in the regulations as well. Discarded, unused commercial chemical products on the P-list at §261.33(e)—and mixtures or formulations containing the chemical as a sole active ingredient—are acute hazardous wastes. Used or spent process wastes on the F-list at 40 CFR 261.31 and identified with a hazard code "H" are also acute hazardous wastes.
Acute Hazardous Waste Affects Your Generator Status
Generators must count acute hazardous waste separately from non-acute hazardous waste. If your site generates greater than 1 kg of acute hazardous waste in a calendar month, then the whole site is a large quantity generator (LQG) and must comply with the requirements for LQGs in 40 CFR 262.17. The LQG exemption has the most stringent rules for RCRA training, reporting, contingency plans, onsite accumulation, and more.In addition, accumulating more than 1 kg of acute hazardous waste onsite at any one time can have repercussions. A small or very small quantity generator would have to manage their acute hazardous waste according to the LQG exemption. (See 40 CFR 262.14(a)(3)).
Note: A 1 kg accumulation limit for acute hazardous waste for SQGs is effective as of March 21, 2025.
Acute Hazardous Waste in RCRA Satellite Areas
According to the satellite rules for LQGs and SQGs at 40 CFR 262.15, a generator may accumulate up to 1 kg of physically solid acute hazardous waste or 1 quart of liquid acute hazardous waste at or near the initial point of generation without triggering additional management requirements. This contrasts with the 55-gallon threshold for non-acute hazardous waste.Understanding the distinction between acute hazardous waste and non-acute hazardous waste is essential to accurately determine your RCRA generator category and properly manage your site's hazardous waste. Generating or accumulating even small amounts of these wastes can subject your facility to more stringent management requirements.
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Stay sharp and network with your peers at Lion’s next two-day RCRA Hazardous Waste Management Workshop near you. Save your seat now to help meet EPA's annual training mandate for hazardous waste personnel (40 CFR 262.17).Find a Post
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