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Identify Waste by Knowledge and Research

Generator Knowledge

You do not always need a laboratory to test your waste. You can designate a waste by comparing its physical properties to definitions and lists in the regulations. For example, a liquid waste with a flashpoint under 140 degrees F has the characteristic for ignitability (and is a dangerous waste), according to the definition for ignitability found in the regulations. "Knowledge" can be used if the information is sufficient to reliably substitute for direct testing of the waste. For instance, knowing which chemicals were used to manufacture a product can help determine whether residues from the process are dangerous or whether a test may be dropped from the testing regime.

You can use knowledge about manufacturing chemicals and processes when available information makes clear that the waste is a dangerous waste or proves that it’s not a dangerous waste. You can use material-safety data sheets (MSDS) or technical reports to find information about a substance's dangerous properties.

You will need to test the waste when knowledge about the waste is limited or when manufacturing process inputs vary. Lab testing can be expensive, so use generator knowledge as much as possible to avoid testing. The more knowledge you have about a waste, the fewer lab tests are needed.

Generator knowledge can come from:

• Historical Sources—Wastes coming from sources with historically high levels of toxic components can continue to be managed as dangerous waste. For example, older painted surfaces can have extremely high levels of lead. They can be managed as a lead D008 dangerous waste without being re-tested for the toxic component.
• Previous Testing—Previous test results can be used, as long as the process generating the waste remains the same.

Washington State Criteria Waste Research

Washington state designation requirements exceed those of the Environmental Protection Agency. In some cases, businesses will need to determine if their waste is toxic or persistent by state criteria. You may do this by book designation or bioassay testing for the state toxic criteria, and persistence-criteria testing.

Book Designation for Toxicity

The most common way to designate for state toxic criteria is Book Designation, described in "Dangerous waste criteria" at WAC 173-303-100(5) of the Dangerous Waste Regulations. You need to know the chemical components in the waste and their concentration, either by testing or by your own knowledge. This method uses Internet databases listing acute animal and fish toxicity test results for individual chemicals. Once you know the identity of chemicals in the waste, their concentrations and the toxicity test results, you plug the information into an equivalency concentration formula to determine if you have a state criteria toxic waste.

Bioassay Testing for Toxicity

If knowledge about a waste is lacking, you do biological testing for toxicity on a representative sample. The acute fish toxicity test is the most common test performed. This test measures fish mortality caused by the waste sample. More rarely, the oral rat toxicity test is used as a biological test method.

Persistence Criteria Testing

In some cases, wastes need to be tested for state persistence criteria. This is usually required when the waste does not designate as a listed, characteristic, or state toxic criteria waste. These wastes will designate under state criteria for persistence if they:

• Contain greater than 0.01% (100 ppm) of one or more of the persistent polycyclic aromatic hydrocarbon (PAH) chemicals listed in the regulations.
• Contain greater than 1% (10,000 ppm) persistent halogenated organic compounds (HOC), as defined in the regulations.          

Related information

Chemical Testing Methods for Designating Dangerous Waste is an Ecology publication that describes acceptable test methods in detail.

Washington Dangerous Waste Designation Tool is a downloadable Excel spreadsheet that will walk a generator through the process of assigning waste codes to dangerous waste.

Which Rules Apply? discusses generator status based on the amounts and types of waste generated.

Report Waste briefly discusses waste codes needed for Annual Dangerous Waste Reporting.

Designation of Dangerous Waste is at WAC 173-303-070 of the Dangerous Waste Regulations.

Excluded Categories of Waste is at WAC 173-303-071 of the Dangerous Waste Regulations.

Procedures and bases for exempting and excluding wastes is at WAC 173-303-072 of the Dangerous Waste Regulations.

Dangerous waste characteristics is at WAC 173-303-090 of the Dangerous Waste Regulations.

Dangerous waste criteria is at WAC 173-303-100 of the Dangerous Waste Regulations.

Waste Identification is an Environmental Protection Agency site that offers guidance on designating Federal Hazardous Waste. Washington state rules are similar, but include state-only wastes. 

Test Methods is an Environmental Protection Agency site that provides resources about testing waste.