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Previous by Date: Subject: Re: [DCHAS-L] Evolution of chemical law and toxicology... Date: Tuesday, May 21, 2019 at 7:54:00 PM Author: "Votaw, James G." <votaw**At_Symbol_Here**KHLAW.COM> |
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Dan,
I don’t know of an easy to understand guidance available. The rules are not that difficult to follow.
Unspent Methanol (Methyl Alcohol CAS #67-56-1) carries a U154 RCRA Listed hazardous waste code.
If the methanol OR xylene is spent, then add the F003 listed hazardous waste code for spent non-halogenated solvents will also apply.
If the flashpoint of the mixture is <60 degrees C or 140 degrees F (as determined by a Pensky-Martens Closed Cup Tester or Setaflash Closed Cup tester depending upon the ASTM Standard Method Used), then it will also carry a D001 waste code for ignitability.
One waste from a specific process can carry multiple hazardous waste codes. Ohio EPA essentially mimics the Fed, but a concise guide to identifying your hazardous waste can be found at https://epa.ohio.gov/portals/32/pdf/ID%20haz%20waste.pdf.
I don’t know which state you are in or if it is a primacy state. Ohio, as well as the Fed’s do have resources available to assist you in properly classifying, or at least verifying the classification(s) that you are provided through compliance assistance programs. If you are having problems, I would encourage you to clarify your classifications with your regulator. Utilize the free resources that are available. I’ve worked in this field for awhile and honestly don’t believe the regulators are there to “burn you” and have found that if you have asked for clarifications and received responses in writing (even e-mail) the regulatory peers significantly recognize that when they come on-site for an inspection. Even the regulators come into situations that they have to seek clarifications on at times. When they do, I found they have appreciated the fact that you have done your due diligence!
Regardless I would advise to document! If your not sure of flashpoints, have a test accomplished by an accredited lab. My experience is <$40 each. All of this will provide supporting documentation when you are inspected.
If the inspector then disagrees with you, collect split samples and have your own tests run. The regulators are human as well!
I hope this helps.
BruceV
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Dan Nowlan
Sent: Tuesday, May 21, 2019 4:36 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Evolution of chemical law and toxicology...
Ugh, I'm so bad at RCRA. IDK if it's truly that confusing or if I just try to get too "cute" drilling deep down into the classifications and confuse myself. If I have an immersion cleaner with methanol and/xylene that is spent (or, sometimes, maybe it's unspent), I struggle on how to classify. Is there easy-to-understand-guidance out there?
Dan
Sent via the Samsung Galaxy S7, an AT&T 4G LTE smartphone
-------- Original message --------
From: "Stuart, Ralph" <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Date: 5/21/19 4:18 PM (GMT-05:00)
Subject: Re: [DCHAS-L] Evolution of chemical law and toxicology...
> Perhaps closer to what you are looking for can be found in the history of "hazardous waste." As proposed in 1978, there were nine characteristics. Just in time for the 1980 presidential season, the 'final' regulations with only four characteristic wastes -- D001, D002, D003, D004--D043.
This is a fascinating example, since it was designed to be as objective and technical as possible while balancing hazard information with available control technology at the time. However, neither the hazard information or the control technologies have remained the same over the last 40 years (EPA can't even agree with OSHA about what flammable means) and the RCRA system has a hard time keeping up with both types of changes, leading to some counter-intuitive interpretations. At the same time, RCRA has done a good job of establishing and supporting the development of a hazardous waste system in the US and the environment in general is much better off for it.
If you had time on your hands and wanted to focus on the evolution of RCRA over time, that would be a rich source of information on the nature and history of chemical regulation.
- Ralph
Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859
ralph.stuart**At_Symbol_Here**keene.edu
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