Any substance that no longer serves its intended purpose and is destined for disposal should be evaluated by the generator to determine if it meets the definition of a hazardous waste. Every possible effort shall be made by the department to identify each waste stream. Unknowns can be accepted by the Hazardous Waste Officer conditionally, but may be returned to the generating department for chemical analysis if the hazardous waste contractor cannot categorize the waste through on-site tests. DO NOT GUESS AT THE IDENTITY OR “CREATE” A NAME FOR AN UNKNOWN! A wrongly identified waste, if released accidentally to the environment, if exploding during disposal, or if causing the fouling of an incinerator pollution control system, not only will harm life and property, but could result in potential litigation. Likewise, the indiscriminate discarding of unknown chemical substances can have equally serious consequences.

NOTE:  All radioactive waste, including those radioactive wastes that meet the definition for a hazardous waste, must be processed through Clemson University’s program for radioactive waste disposal.

The following sources shall be used to accurately characterize a waste stream:

  • Section II of this Manual,
  • Safety Data Sheets (SDS),
  • Process Knowledge.

In the event that a waste chemical substance does not meet the regulatory definition of a RCRA hazardous waste, yet the generator recognizes unique hazardous characteristics which are not subject to other regulatory requirements, the generator shall contact the Hazardous Waste Officer (656-1770 or 656-0341) to determine if the waste substance should be disposed as a hazardous waste. Many hazardous chemicals may not be RCRA regulated but may be regulated by other laws and disposal restrictions.

Hazardous Waste Determination Procedures

Waste material, which may be a hazardous waste, is generated within three primary activities at Clemson University. These activities include:

  • teaching
  • research projects
  • physical plant operations and maintenance.

The generators in these areas are responsible for properly characterizing the waste generated to determine if it is a hazardous waste. These activities generate three general categories of hazardous waste:

  • off-specification chemical stock,
  • research effluent and residue,
  • facility operations and maintenance waste (e.g., paint related waste).

A Hazardous Waste Determination will be documented on the Pick Up Request and serve as the Documentation that the Generator had made this determination before any waste is moved by the Office of Research Safety Hazardous Waste Personnel to the Central Accumulation Point. No waste can or will be picked up without this document.

The waste characterization process is defined in Figures II-1 through II-10. These flow charts guide the user through a systematic decision-making process for categorizing the wastes. Note that a waste stream may belong to more than one category; therefore, follow all of the flow charts in order to properly characterize the waste. This process is discussed in more detail in the following sections.




Solid Waste

The first question to be answered when defining a waste stream is: “Is this material a solid waste?” A solid waste is any solid, semi-solid, liquid or contained gaseous material that is discarded or considered “inherently waste-like” (R.61-79.261.2). Materials, which are solid wastes, are identified in Figure II-1.

Several types of materials are specifically excluded from the definition of solid waste under R.61-79.261.4. These waste types are listed in Figure II-2. Some recycled materials are also exempt from the definition of a solid waste. Some materials when recycled are solid wastes and others are not; these materials are defined in Figure II-3.

After reviewing Figures II-1, II-2 and II-3 classify the waste stream as either a solid waste or not a solid waste. If it is a solid waste, proceed to Section II.B.2. and determine if the waste is also a hazardous waste or if other regulatory programs (such as the Toxic Substances Control Act (TSCA) regulate it. If the material is not a solid waste, it may still be a miscellaneous regulated waste; therefore, proceed to Section II.B.2.

Hazardous and Miscellaneous Regulated Wastes

In order for a waste material to be a hazardous waste, it must first meet the definition of a solid waste (Section II.B.1.). Figure II-4 outlines the procedure for determining which solid wastes are also hazardous wastes. There are two different ways a waste can be classified as a hazardous waste. It can be a listed hazardous waste and/or it can be a characteristic hazardous waste. Figure II-5, along with the tables in R.61-79.261.31 through 261.33, define listed hazardous wastes. If a waste is included in any of these lists, and in the case of U and P listed wastes it is un-used, it is a listed hazardous waste. These lists are as follows:

  • F-listed waste from operations that are not specific to a particular manufacturing operation (R.61-79.261.31). Example: Spent halogenated solvents used in degreasing.
  • K-listed waste from specific manufacturing process (R.61-79.261.32). Example: Sludge from wood preserving.
  • P-listed acute hazardous commercial chemical products (R.61- 79.261.33(e)).
  • U-listed toxic commercial chemical products (R.61-79.261.33(f)).

It is also necessary to determine if a waste is a characteristic hazardous waste. The four hazardous waste characteristics are:

  • ignitability,
  • corrosivity,
  • reactivity,
  • toxicity

To determine if a solid waste exhibits the characteristics of ignitability, follow Figure II-6. Use Figure II-7 to determine if the waste exhibits the characteristics of corrosivity, and Figures II-8 and II-9 to determine if the waste exhibits the characteristics of reactivity and toxicity, respectively. If a waste exhibits any of the above four characteristics, it is a characteristic hazardous waste. A waste may be both a listed and a characteristic hazardous waste.

The generator of the waste must also determine if it is regulated under TSCA or any other applicable federal or state laws or regulations. A waste does not necessarily have to be defined as a solid waste in order to belong in these categories. Use Figure II-10 to determine if the waste belongs in these additional waste categories.

Empty Containers

Residues of hazardous waste remaining in a container may not be subject to the requirements specified in this manual if the container meets the regulatory definition of an empty container.

A container or an inner liner removed from a container that has held a hazardous waste, except a compressed gas or acute hazardous waste, is empty if:

  • All wastes have been removed that can be removed using common practices (e.g., pouring, pumping, aspirating), and
  • No material pours out of the container when held upside down or for Department of Transportation (DOT) recycling, no more than 2.5 cm (one inch) of residue remain on the bottom of the container or inner liner, or
  • No more than 3% by weight of the total capacity of the container remains in the container or inner liner if the container is less than or equal to 100 gallons, or
  • No more than 0.3% by weight of the total capacity of the container remains in the container or inner liner if the container is greater than 100 gallons in size.

A container that has held a hazardous waste that is a compressed gas is empty when the pressure in the container approaches atmospheric pressure.

However, it should be noted that releasing hazardous waste from a compressed gas cylinder for the purpose of returning the cylinder to atmospheric pressure is considered illegal discharge of a hazardous waste.

CAUTION! A container or an inner liner removed from a container that has held a P-listed or acute hazardous waste (as identified in Appendix A) is not considered empty until:

The container or inner liner has been triple rinsed using a solvent capable of removing the waste,

 The container or inner liner has been cleaned by another method that has been shown in the scientific literature, or by tests conducted by the generator, to achieve equivalent removal, or

 In the case of a container, the inner liner that prevented contact of the acute hazardous waste with the container has been removed.

The rinsate generated when cleaning hazardous material from an acute hazardous waste containers, should be managed in accordance with the requirements specified in this manual unless it can be determined, using the procedures outlined in this section, that the material is not a hazardous waste. NORMALLY, ALL RINSATE FROM ACUTE HAZARDOUS WASTE CONTAINERS IS AN ACUTE HAZARDOUS WASTE AND SHOULD BE COLLECTED AND MANAGED ACCORDINGLY.

For disposal of empty containers into landfill at Clemson University see Appendix D for guidance on defacing. Recycling should be investigated.