Step 5: Check Washington State-only Criteria
Step 5 tools:
Washington State rules are more protective than federal hazardous waste rules. This means in addition to the rules we adopted from the federal Resource Conservation and Recovery Act (RCRA), Washington adds our own requirements. Wastes may designate as “dangerous” due to toxicity or persistence. These “state-only” waste codes start with the letter W—WT for toxic or WP for persistence (for example, WP01).
Washington Toxic Criteria
Washington toxic criteria wastes are coded WT01 or WT02, depending on the concentration of its toxic constituents. WT01 wastes have a 2.2 quantity exclusion limit (QEL) – learn more about QEL and generator status. Details about WT01 and WT02 wastes are in the regulations (WAC 173-303-100).
You can test for this using a bioassay, which means a laboratory will use a sample of your waste to determine if it kills fish or other animals at a certain concentration.
Alternatively, you may be able to use a toxicity database to determine if it’s a Washington State toxic. These databases show the results from previous tests for specific chemicals on animals. You’ll need to know the concentration of specific chemicals in your waste. If you use information from such databases, you must use the most conservative results. If data are available for more than one test endpoint (that is, fish, oral rat, inhalation rat, or dermal rabbit), the value with the highest toxicity must be used. Results from tests on salmonids (the family of fish that includes salmon, trout, and other fish) must be used before tests on minnows, which must be used before tests on other animals.
Once you get sample test results from a database, you need to use the equation in the regulations (WAC 173-303-100) to calculate the equivalent concentration to compare it to the Toxic Category Table in the regulations.
Biological Testing Methods for the Designation of Dangerous Waste is a publication that describes testing requirements. For example, tests on fish must be conducted for at least 24 hours.
Washington Persistence Criteria
Check your Safety Data Sheet (SDS or MSDS) and look for these chemicals or their prefixes (bromine, chlorine, fluorine, or iodine). For example, chloromethane. If you have compounds with those names, is it a halogen? If yes, you can assume it is dangerous waste or you can test it.
WPCB Code – Washington Polychlorinated Biphenyls
WSC2 – Solid Corrosives
Solid corrosives are not common. Cement or lime, for example, may test as corrosive.
Contact a compliance specialist at your regional office with questions about designating or managing your dangerous waste.
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