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Spontaneous Combustion: Not Just Science Fiction!

Posted on October 8,2018 by Roseanne Bottone

In July, I shared some insight about how to treat D001 ignitable liquids, on-site, without a permit. I’m back this week with another piece that will excite fans of D001 ignitable wastes.

This time, I cover a second type of ignitable waste, non-liquid D001s.

See my original D001 post here.

Earlier this year, we talked about one of the main criteria used to classify or identify liquid ignitable wastes—flash point.  If you remember, a liquid with a flash point of less than 60 °C (140 °F) is considered an D001 ignitable hazardous waste.

Recap: The Four Types of D001 Wastes

fire-big.pngThe RCRA regulations, at 40 CFR 261.24, provide classification criteria for four types of ignitable hazardous wastesliquids with low flash points, non-liquids, compressed gases, and oxidizers. Today we will focus on cool facts about the second type: Non-liquids. Check this space in the weeks to come for my articles about ignitable compressed gases and ignitable oxidizers.

Meet EPA’s RCRA training mandate with trusted, in-depth training for hazardous waste professionals in Cleveland, Atlanta, Pittsburgh, Detroit, Orlando, Nashville, Dallas, Charlotte, and Houston this month!

What is a Non-liquid D001?

The RCRA hazardous waste regulations define a non-liquid D001 waste as a material that is not a liquid and is capable, under standard temperature and pressure, 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.

No Test Criteria

Here’s something that may come as a surprise: RCRA does not specify any test criteria for this category!

Per 40 CFR 262.11(d)(1) waste identification can be done based on generator knowledge using “other reliable and relevant information about the properties of the waste or its constituents.”

Testing is not required. However, both the Occupational Safety and Health Administration (OSHA) and the Department of Transportation (DOT) specify analytical criteria for flammable solids for their classification systems. These can be helpful sources of information.

How OSHA and DOT Classify Non-liquid Flammables

OSHA classifies a flammable solid using Method N.1 as described in Part III, sub-section 33.2.1 of the UN ST/SG/AC.10 (incorporated by reference; See 29 CFR 1910.6).

The DOT’s standards for Class 4 materials are specified at 49 CFR 173.124. In transportation, these materials are regulated as Division 4.1 Flammable Solid, Division 4.2 Spontaneously Combustible, or Division 4.3 Dangerous When Wet.  

Examples of Non-liquid D001 Wastes

greek-fire-god.jpgExamples of non-liquid D001 wastes include a broad array of materials—from desensitized explosives to common matchbooks, and more, like:  
  • Metal powders (e.g., aluminum)  
  • Magnesium and phosphorous  
  • Celluloid (old film in block, rods, rolls, sheets, tubes, etc.)
  • Polymerizing materials
  • Pyrophoric materials*
*Scholars of ancient Greece may recognize “Pyrophoric” as a word of Greek origin that means “carrier” or “bearer” of fire.

Choosing the Right Fire Extinguisher

This is very important: If you use a water or carbon dioxide fire extinguisher on fires from some flammable metals such as lithium, sodium, or potassium, it can fuel the fire!

You’ll need to have a class D extinguisher on hand.

For more about choosing and using fire extinguishers in the workplace, check out these two posts:
OSHA Rules for Fire Extinguishers
Fighting Fire in the Workplace

Advanced RCRA Training for Experienced Pros

The Advanced RCRA Hazardous Waste Management Workshop brings together experienced environmental professionals to explore methods to minimize waste, control pollution, and find relief from burdensome RCRA requirements.

Join your peers to discover new ways to cut costs without running afoul of the hazardous waste regulations and limit your exposure to liability under programs like CERCLA.

Don’t miss the Advanced RCRA workshop when it comes to Pittsburgh on Oct 19, Dallas on October 26, Houston on November 1, and Philadelphia on December 14!

See all RCRA training options at

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