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In some circumstances "knowledge" of a waste can be used to designate a waste. The knowledge must be based on demonstrable facts that apply to the particular waste - likely contaminants or ingredients in a process or effects of a process.
Knowledge is necessary to designate for the listed discarded chemical products, and listed source dangerous waste codes.
Knowledge is useful to designate for the dangerous waste characteristics waste codes. It can be substituted for dangerous waste toxicity and persistence testing.
| If you know a waste is a dangerous waste in Washington State. |
Testing is not required. Apply the waste codes that apply based on
your knowledge.
Keep the records verifying that the waste is hazardous for five years. Dispose of the waste as required by applicable dangerous waste requirements |
| If you know a waste is not a dangerous waste in Washington State. |
Testing is not required.
Keep the records verifying that the waste is not hazardous for five years. Dispose of the waste as solid waste. |
Results from test methods that are different than the Dangerous Waste methods can be used as designation knowledge under some circumstances.
Example - Knowledge from a lead abatement screening test used to avoid a Dangerous Waste test:
If a test of the lead content on a surface by the methods required under lead abatement rules shows that lead is not present - there is no need to run a TCLP test which is required to show the lead would not leach out of the waste after disposal.
Material Safety Data Sheets can be used with products that have them. The MSDS can only be used to designate the product. It would not apply to paint or other waste that is mixed with a product. Some MSDS information will include any federal waste codes that would apply to the product when it is discarded.
Example - Knowledge used to designate a product:
Knowledge of a paint stripping solvent can be based on the MSDS that came with the solvent. Testing is not necessary.
Knowledge of the paint that is being removed depends on knowing what is in the paint.
If it is new paint and the MSDS is available or the label has all the ingredients listed the MSDS information or label can be used as knowledge.
If the paint ingredients are unknown then knowledge alone cannot be used to designate that part of the waste stream. However, test results from a screening test or XRF device can give alternate test knowledge. (See Example 1 above.)
If the paint was consumer or residential paint, and the painted surface is newer than 1978 lead in the paint is less likely.
If the paint was older than 1978, was non-consumer paint applied later than 1978, or was on an industrial surface or steelwork it may designate for lead.
Refer to the section Clues to Designation Knowledge for information about knowledge that can be gained from:
Paint waste old enough to be contaminated with lead or mercury at a regulated site can be disposed of as a dangerous waste instead of paying for testing and also paying for disposal.
Example - Knowledge used to designate a waste:
A garage floor where cars were spray painted for many years could be handled as if it contained TCLP metal wastes without testing because there is good circumstantial evidence that the contamination was there and that the floors would designate.