The Environmental Protection Agency (EPA) has established two ways of identifying solid wastes as hazardous under the Resource Conservation and Recovery Act (RCRA) regulations; keeping in mind that according to EPA’s definition of a solid waste, a solid waste can be either a liquid or solid.

First, a waste may be considered hazardous if it exhibits certain hazardous properties or “characteristics.” EPA’s regulations define four hazardous waste properties that, if exhibited, identify a waste as a “characteristic hazardous waste”. They include Ignitability, Corrosivity, Reactivity, and Toxicity

The second way to tell if a waste is hazardous is if it is included on a specific RCRA list that EPA has determined are hazardous. These “listed wastes” are placed on a list because EPA finds them to pose substantial present or potential hazards to human health or the environment, as summarized below.

4 Lists of Hazardous Wastes

  • F Listed Wastes (non-specific source wastes) – The F list designates as hazardous particular solid wastes from certain industrial or manufacturing processes. Because the processes producing these wastes can occur in different sectors of industry, the F list wastes are known as wastes from nonspecific sources. Wastes included on the F list are found at 40 CFR 261.31.
  • K Listed Wastes (source-specific wastes) – The K list designates particular solid wastes from certain specific industries as hazardous. Wastes included on the K list are found at 40 CFR 261.32.
  • P and U Listed Wastes (discarded commercial chemical products) – These two lists are similar in that both list certain commercial chemical products as hazardous when they are discarded or intended to be discarded. These listings consist of commercial chemical products having the generic names listed, off-specification species, container residues, and spill residues. The difference is that the chemicals on the P list are identified as acute hazardous wastes and those on the U list are identified as toxic wastes. Some chemicals on both lists may also be designated to have other properties. Wastes included on the P and U lists can be found at 40 CFR 261.33.

These four lists each designate anywhere from 30 to a few hundred waste streams as hazardous. Each waste on the lists is assigned a waste code consisting of the letter associated with the list followed by three numbers. For example, the wastes on the F list are assigned the waste codes F001, F002, and so on. These waste codes are an important part of the RCRA regulatory system. Assigning the correct waste code to a waste has important implications for the management standards that apply to the waste.

The wastes on the F and K lists can be divided further into subgroups.

F Listed Waste Groupings

It may be helpful to consider that the wastes on the F list are divided into seven subgroups, generally depending on the type of manufacturing or industrial operation that creates them. The seven general subgroups of F listed wastes are:

  • Spent solvent wastes (F001 – F005)
  • Wastes from electroplating and other metal finishing operations (F006 – F012, and F019)
  • Dioxin bearing wastes (F020 – F023 and F026 – F028)
  • Wastes from production of certain chlorinated aliphatic hydrocarbons (F024 and F025)
  • Wastes from wood preserving (F032, F034, and F035)
  • Petroleum refinery wastewater treatment sludges (F037 and F038)
  • Multisource leachate (F039)

K Listed Waste Groupings

The wastes on the K list are divided into 13 subgroups of wastes from specific sources. The 13 subgroups of K-listed wastes are:

  • Wood preservation (K001)
  • Inorganic pigment manufacturing (K002 – K008)
  • Organic chemicals manufacturing (K009 – K011, K013 – K030, K083, K085, K093 – K096, K103 – K105, K107 – K118, K136, K149 – K151, K156 – K159, K161, K174 – K175, and K181)
  • Inorganic chemicals manufacturing (K071, K073, K106, and K176 – K178)
  • Pesticides manufacturing (K031 – K043, K097 – K099, K123 – K126, and K131 – K132)
  • Explosives manufacturing (K044 – K047)
  • Petroleum refining (K048 – K052, and K169 – K172)
  • Iron and steel production (K061 and K062)
  • Primary aluminum production (K088)
  • Secondary lead processing (K069 and K100)
  • Veterinary pharmaceuticals manufacturing (K084 and K101 – K102)
  • Ink formulation (K086)
  • Coking (K060, K141 – K145, and K147 – K148)

In addition to the above, the EPA may determine that a solid waste is hazardous if the waste:

  • Exhibits any of the hazardous waste characteristics, i.e., ignitability, corrosivity, reactivity, or toxicity.
  • Is “acutely” hazardous (e.g., if it is fatal to humans or animals at low doses, 40 CFR 261.11(a)(2)).
  • Contains any of the toxic constituents listed in 40 CFR part 261, Appendix VIII and, after consideration of various factors described in the regulation, is capable of posing a “substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed” (40 CFR 261.11(a)(3)).EPA will place a substance on the list of hazardous constituents in Appendix VIII if scientific studies have shown the substance has toxic effects on humans or other life forms.

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