Determining if a chemical waste meets the regulatory definition of a hazardous waste can be difficult and requires specific training. Therefore, it is the UMN policy that all staff assumes that all chemical wastes are hazardous and must be managed by HSRM for proper disposal unless told otherwise. Chemical wastes should never be thrown in the trash or poured down the drain without first seeking permission from HSRM. While it is the UMN policy to assume all chemical waste is hazardous, this section describes the details of how hazardous waste is defined by the EPA and MPCA.
There are two criteria to determine if a waste is classified as hazardous waste. First, determine if the waste exhibits one or more of the following characteristics: ignitability, corrosivity, reactivity, or toxicity. Second, determine if the waste is listed by the EPA as a hazardous waste.
Characterisitic Hazardous Waste:
Characteristic hazardous waste is waste that is ignitable, oxidant, corrosive, reactive, toxic, or lethal. The specific criteria for characteristic hazardous waste are listed in Table 8.1. A waste is considered to exhibit the characteristic of toxicity if it is in concentrations greater than the regulatory thresholds listed in Table 8.2.
Table 8.1 – Criteria and Characteristics of Ignitability, Corrosivity, and Reactivity
EPA Waste Code |
Criteria |
Ignitable (D001) |
A waste that meets any of the following criteria:
|
Oxidizer (D001) |
A waste that meets any of the following criteria:
|
Corrosive (D002) |
A waste that meets any of the following criteria:
|
Reactive (D003) |
A waste that meets any of the following criteria:
|
Toxic (D004 – D043) | See Table 8.2 |
Lethal (MN01) |
A waste that meets any of the following criteria:
|
Table 8.2 – Criteria and Characteristics of Toxicity
EPA Waste Code |
Chemical Name |
Regulatory Threshold (mg/L) |
EPA Waste Code |
Chemical Name |
Regulatory Threshold (mg/L) |
D004 | Arsenic | 5.0 | D024 | m-Cresol | 200.0 |
D005 | Barium | 100.0 | D025 | p-Cresol | 200.0 |
D006 | Cadmium | 1.0 | D026 | Cresol | 200.0 |
D007 | Chromium | 5.0 | D027 | 1,4-Dichlorobenzene | 7.5 |
D008 | Lead | 5.0 | D028 | 1,2-Dichloroethane | 0.5 |
D009 | Mercury | 0.2 | D029 | 1,1-Dichloroethylene | 0.7 |
D010 | Selenium | 1.0 | D030 | 2,4-Dinitrotoluene | 0.13 |
D011 | Silver | 5.0 | D031 | Heptachlor (and its epoxide) | 0.008 |
D012 | Endrin | 0.02 | D032 | Hexachlorobenzene | 0.13 |
D013 | Lindane | 0.4 | D033 | Hexachlorobutadiene | 0.5 |
D014 | Methoxychlor | 10.0 | D034 | Hexachloroethane | 3.0 |
D015 | Toxaphene | 0.5 | D035 | Methyl ethyl ketone | 200.0 |
D016 | 2,4-D | 10.0 | D036 | Nitrobenzene | 2.0 |
D017 | 2,4,5-TP (Silvex) | 1.0 | D037 | Pentachlorophenol | 100.0 |
D018 | Benzene | 0.5 | D038 | Pyridine | 5.0 |
D019 | Carbon tetrachloride | 0.5 | D039 | Tetrachloroethylene | 0.7 |
D020 | Chlordane | 0.03 | D040 | Trichloroethylene | 0.5 |
D021 | Chlorobenzene | 100.0 | D041 | 2,4,5-Trichlorophenol | 400.0 |
D022 | Chloroform | 6.0 | D042 | 2,4,6-Trichlorophenol | 2.0 |
D023 | o-Cresol | 200.0 | D043 | Vinyl Chloride | 0.2 |
Listed Hazardous Waste:
Wastes may be hazardous if the EPA specifically lists them on of four lists for hazardous waste:
- F list
- K list
- P list
- U list
The F list includes wastes from nonspecific sources. At the UMN, the most common F listed waste is waste generated from the use of organic solvents. This includes waste mixtures of organic solvents and debris and/or media contaminated with organic solvents. Table 2.3 lists the most common F listed wastes found at the UMN.
Table 8.3 – Common Listed Hazardous Wastes from Non-Specific Sources (F001 – F005)
EPA Waste Code |
Waste Listing |
F001 (Spent solvents used in degreasing) | 1,1,1-trichloroethane, carbon tetrachloride, chlorinated fluorocarbons, methylene chloride, trichloroethylene |
F002 (Spent solvents) | 1,1,1-trichloroethane, 1,1,2-trichloro-1,1,2-trifluoroethane, 1,1,2-trichloroethane, chlorobenzene, methylene chloride, o-dichlorobenzene, tetrachloroethylene, trichlorofluoromethane |
F003 (Spent solvents) | Acetone, cyclohexanone, ethyl acetate, ethyl ether, methanol, methyl isobutyl ketone, n-butyl alcohol, xylene |
F004 (Spent solvents) | Cresols, cresylic acid, nitrobenzene |
F005 (Spent solvents) | 2-ethoxyethanol, 2-nitropropene, benzene, carbon disulfide, isobutyl alcohol, methyl ethyl ketone, pyridine, toluene |
The K list includes wastes generated from specific industrial process and is not typically applicable at a university setting.
The P list (Appendix A) and the U list (Appendix B) include pure or commercial grade formulations of specific unused chemicals. Chemicals on the P list are considered acutely toxic and chemicals on the U list are considered toxic. Chemicals on both the P and U lists can also display other characteristics, such as ignitability, corrosivity, reactivity, and toxicity.