Frequent Questions

Does the waste code for a waste listed solely for the characteristic of ignitability, corrosivity, and/or reactivity apply if the waste does not exhibit any hazardous waste characteristics at the point of generation?

When a waste is generated that meets a listing description of a hazardous waste listed only for exhibiting the characteristic of ignitability, corrosivity, and/or reactivity, the waste is not hazardous if it does not exhibit a characteristic (§261.3(g)(1)).  For example, F003 is listed solely for the characteristic of ignitability.  If a waste is generated and meets the listing description for F003 but does not exhibit the characteristic of ignitability at the point of generation, it is not regulated as a hazardous waste (Monthly Call Center Report Question; October 2002 (RO 14638)). (PDF 10K)  Furthermore, since the waste did not exhibit a characteristic at the point of generation, it was never a hazardous waste and is not subject to the land disposal restrictions in Part 268 (66 FR 27266, 27286; May 16, 2001).

The Hazardous Waste Identification Rule (66 FR 27266; May 16, 2001) is available at the following URL:

http://www.epa.gov/epawaste/hazard/wastetypes/wasteid/hwirwste/fedreg.htm

Additional guidance regarding wastes listed solely for exhibiting the characteristic of ignitability, corrosivity, or reactivity is available in the following documents:

Memo, Dellinger to Smith; March 18, 2003 (RCRA Online 14654)
Call Center Monthly Report Question; January 2002 (RCRA Online 14592) [PDF 8K]
Memo, Cotsworth to Nebrich; December 11, 2001 (RCRA Online 14579) [PDF 5K]

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