Step One: Get Ready to Designate
Get the Safety Data Sheets (SDS or MSDS) for any products that go into your waste stream
Is it Waste?
If you don’t have a use for something and it will be discarded, it’s a waste. But before you throw it in a dumpster or down the drain, you need to know if it’s dangerous and how you can legally dispose of it.
If your waste is product that will be used, it may not be waste. Learn the difference between waste and products.
Is Your Waste a Solid Waste?
Almost all wastes are called “Solid Waste” in the regulations unless they are specifically excluded from the definition of solid waste. That doesn’t mean the waste is in a solid state. It might be liquid, compressed gas, or semi-solid.
Use the definitions and descriptions in the Dangerous Waste Regulations (WAC 173-303-016). If it’s not a “solid waste,” it cannot be a dangerous waste.
Gather Information About Your Waste
If you have a “solid waste,” then get ready to designate. You already know a lot about your waste, like what process created it or what products go into it. You need:
- A list of wastes at your facility and what you know about them. Consider the source of the waste. What processes created the waste? Were any products or other wastes mixed in?
- The Safety Data Sheets (SDS or MSDS) for products that go into your waste stream. These are provided by the product manufacturer. A waste may not have the same qualities or constituents as it did when it was a product, but the SDS is a good place to start. Even if the SDS says the product is not hazardous, you may still need to check if it qualifies as a dangerous waste.
From the SDS, you’ll find information like pH, flashpoint, and other physical specifications. Some SDS can also tell you about toxicological information from previous testing. Information in the stability section might give you the clue that it’s reactive if the Department of Transportation (DOT) considers it reactive. You may see rating systems that tell you it’s ignitable.
Example: you use a solvent to clean a greasy part. The SDS tells you the solvent’s flash point is 25 degrees Fahrenheit, so it’s highly ignitable (which means it will have a D001 waste code). But you must also consider what types of contaminants the solvent picked up from the part. For example, if the part has paint on it and that paint has chrome in it, it might designate for a waste code of D007.
Sometimes you don’t have enough information about your waste to designate, so you have to send a sample to a laboratory for testing. Learn more about testing waste.
Contact a compliance specialist at your regional office with questions about designating or managing your dangerous waste.