Spontaneous Combustion: Not Just Science Fiction!
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
The RCRA regulations, at 40 CFR 261.24, provide classification criteria for four types of ignitable hazardous wastes—liquids 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!
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.
What is a Non-liquid D001?
Here’s something that may come as a surprise: RCRA does not specify any test criteria for this category!
No Test Criteria
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.
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).
How OSHA and DOT Classify Non-liquid Flammables
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
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*
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!
Choosing the Right Fire Extinguisher
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
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.
Advanced RCRA Training for Experienced Pros
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
Energetic/enthusiastic! Made training enjoyable, understandable and fun!
Hazardous Waste Professional
The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!
I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.
Director of Regulatory Affairs
Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.
Chemical Laboratory Manager
The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!
Hazmat Shipping Professional
If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.
This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.
This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.
Waste Management Professional
This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.
I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.
Download Our Latest Whitepaper
In most cases, injuries that occur at work are work-related and must be recorded to maintain compliance with OSHA regulations. This report shows you the 9 types of injuries you don’t record.