Search

Spontaneous Combustion: Not Just Science Fiction!

Posted on 10/8/2018 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.png

The 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 ClevelandAtlantaPittsburghDetroitOrlandoNashvilleDallasCharlotte, 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.jpg

Examples 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 fuelthe 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 www.Lion.com/RCRA

Tags: D001, EPA, hazardous, ignitable, RCRA, waste

Find a Post

Compliance Archives

Lion - Quotes

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

David Hertvik

Vice President

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

Frank Papandrea

Environmental Manager

The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!

Brian Martinez

Warehouse Operator

The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information.

Stephanie Venn

Inventory Control Specialist

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

I can't say enough how pleased I was with this course! Everything finally makes sense.

Kim Graham

Lab Manager

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

More thorough than a class I attended last year through another company.

Troy Yonkers

HSES Representative

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

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

Use this guide as a quick reference to the most common HAZWOPER questions, and get course recommendations for managers and personnel who are in need of OSHA-required HAZWOPER training.

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.