Frequent Questions

When must a waste be managed as hazardous waste if the generator is awaiting characterization test results?

Hazardous waste is considered generated when it is first produced or first becomes subject to regulation, not when a generator first analyzes the waste. The generator accumulation time period and regulations apply as soon as waste is produced or when waste is removed from the satellite accumulation area (Memo, Lowrance to Axtell; April 21, 1989 (RCRA Online #11424)). 

This guidance document is available in the RCRA Online database at the following URL:

https://yosemite.epa.gov/osw/rcra.nsf/how+to+use?OpenForm

This guidance represents clarification of the Federal regulations. Since most states are authorized to implement the Federal regulations, you should contact your state agency to acquire additional information on hazardous waste identification. State web sites may be found at the following URL: 

www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies

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