Here are some frequently asked questions about EPA’s listed hazardous wastes.
Acute Hazardous Wastes
Q. What RCRA hazardous wastes are classified as "acute" hazardous wastes?
A. Hazardous wastes listed in accordance with the criteria in 40 CFR 261.11(a)(2) are designated as "acute" hazardous wastes. Acute hazardous wastes are assigned the hazard code (H) (40 CFR 261.30). Specifically, a waste is classified as an acute hazardous waste if it is any P-listed waste (40 CFR 261.33) or one of the following F-listed wastes: F020, F021, F022, F023, F026, and F027 (40 CFR 261.31) (EPA RCRA Hotline, February 2003).
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Contaminated Scrap Metal
Q. Can generators of scrap metal that is contaminated with a listed hazardous waste take advantage of the exemption in 40 CFR 261.6(a)(3)(ii) when recycling the metal?
A. Generators can take advantage of the exemption in 40 CFR 261.6(a)(3)(ii) for scrap metal that is contaminated with listed hazardous waste as long as the material meets the regulatory definition of scrap metal (40 CFR 261.1(c)(6)). However, any residues resulting from the processing of contaminated scrap metal would remain a hazardous waste via the derived-from rule (57 FR 37194, 37237; August 18, 1992)(EPA RCRA Hotline, December 2002).
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Spray Can Solvent Residue
Q. A facility uses spray cans to apply product solvent as a paint thinner. After use, the canisters are not empty pursuant to 40 CFR 261.7(b)(2) because their internal pressure remains higher than atmospheric pressure. When these spray cans are ready to be discarded, they are punctured and drained so the cans can be recycled as scrap metal. Would hazardous waste listings apply to the remaining solvent removed from these spray cans?
A. The unused solvent removed from the spray can may meet a hazardous waste listing. If the remaining solvent in the spray can is located on the P list or the U list in 40 CFR 261.33(e) or (f), the residue could be a listed hazardous waste. Specifically, 40 CFR 261.33(b) states that, "any residue remaining in a container or in an inner liner removed from a container that has held any commercial chemical product or manufacturing chemical intermediate having the generic name listed in paragraphs (e) or (f) of this section, unless the container is empty as defined in Section 261.7(b) of this chapter" is a hazardous waste. However, if the residue is not on the P list or the U list, it may still be hazardous if it exhibits any of the characteristics of a hazardous waste as defined in 40 CFR 261, Subpart C. It is the responsibility of the generator to make this determination (EPA RCRA Hotline, December 2002).