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Previous by Date: Subject: Re: [DCHAS-L] Waste storage question (DCM & Hexanes / EPA Waste Determination) Date: Thursday, August 5, 2021 at 3:32:13 PM Author: "Ryan, Patrick" <patrick.ryan6**At_Symbol_Here**EXCHANGE.MONTANA.EDU>

Next by Date: Subject: [DCHAS-L] Chemical Safety headlines (11 articles) Date: Fri, 6 Aug 2021 06:17:32 -0400 Author: Ralph Stuart

Hi Ralph,

I worked most of my adult life in industry and make distinctions between "flammable" and "combustible" materials, depending on their flashpoint (as per ASTM test(s) and boiling points, in accordance with the NFPA.
DCM is considered non-combustible and of course also non-flammable.

The waste material you are dealing with should be considered "flammable" unless you can prove that it is not. Proof would require ASTM tests over the range of varying compositions and storage conditions. The latter will change the compositions during storage when vapor losses occur; e.g., because of azeotropes or a fire.

Best regards,

Jan Windhorst

-----Original Message-----
From: ACS Division of Chemical Health and Safety On Behalf Of Ralph Stuart
Sent: August 5, 2021 11:38 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Waste storage question

> I prefer to use the Fisher web site to look up safety and SDS information, as everything is clear and easy to understand.

Thanks for sharing that resource. I note that the Fisher SDS states that "Chemical waste generators must determine whether a discarded chemical is classified as a hazardous waste.‰?? Someone else shared a link to a 2016 EPA document that describes the regulatory process for the classification of waste solvents, assuming perfect information is available for the mixture. This guidance is at https://www.epa.gov/sites/default/files/2016-09/documents/version_2_-_solvent_guidance_final_508_compliant_090116.pdf

Unfortunately, we don‰??t have enough specific information available for this waste mixture to use the EPA‰??s resource. So we will be erring on the side of caution and assuming it is flammable.

Thanks to everyone for sharing their thoughts on this question.

- 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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