UNIT I STUDY GUIDEHazardous WasteCourse Learning Outcomes for Unit I Upon completion of this unit, students should be able to: 1. Identify the primary laws that govern hazardous waste operations and discuss how they are applied in workplace situations. 2. Identify hazardous wastes using the EPA-defined characteristics of ignitibility, corrosivity, reactivity, and toxicity. 3. Identify hazardous wastes using the EPA F, K, P, and U lists. 4. Define universal wastes and describe the requirements for handling them. 5. Define the various categories of hazardous waste generators and explain the regulatory requirements that apply to each. 6. Describe the precautions for the safe handling of hazardous waste. 7. Identify and explain strategies for waste minimization. 8. Identify the considerations for selecting hazardous waste transporters and treatment storage and disposal facilities (TSDF). 9. Discuss the process and options available for the remediation of contaminated hazardous waste sites. Reading Assignment Forward: pp. iv-vii Chapter 1: Hazardous Waste EPA Listed Wastes, 40 CFR 261.31-33: http://www.epa.gov/epa waste/hazard/wastetypes/listed.htm Unit Lesson BOS 3125, Hazardous Materials Management 5 (NARA, 2011a) Here we are, ready to start a course titled “Hazardous Materials Management,” but the first course unit and first chapter in the book are titled “Hazardous Waste.” What’s that about? Isn’t hazardous waste at the end of the lifecycle and more appropriate for the end of the course? Besides, safety practitioners aren’t responsible for hazardous waste; that’s an environmental thing, right? In order to manage hazardous materials in the workplace effectively, we need to start with the end in mind; that is, what happens to the material when we are done with it. The Resource Conservation and Recovery Act (RCRA) of 1976 introduced us to the cradle to grave” concept of hazardous materials management by focusing efforts on the final disposal of hazardous substances (Haight, 2012). The improper disposal of industrial waste over many decades had created enormous health and environmental issues, as well as a nearly insurmountable cleanup problem. The Environmental Protection Agency (EPA) has created regulations for the cleanup of contaminated waste sites, but more importantly, has forced industries to think about the materials they use, how they are stored and handled, and how they are to be discarded when no longer needed. The escalating cost of the disposal of hazardous wastes in accordance with EPA rules has caused many industries to change to materials that are less hazardous or change processes so that hazardous materials are no longer needed. Recycling and reuse of hazardous materials has become more cost-effective than disposal. One of the goals of RCRA is to prevent future problems caused by irresponsible waste management (Haight, 2012). This goal is being achieved by managing the full lifecycle of hazardous materials. Sa ...

1. UNIT I STUDY GUIDEHazardous WasteCourse Learning
Outcomes for Unit I
Upon completion of this unit, students should be able to:
1. Identify the primary laws that govern hazardous waste
operations and discuss how they are applied in workplace
situations.
2. Identify hazardous wastes using the EPA-defined
characteristics of ignitibility, corrosivity, reactivity, and
toxicity.
3. Identify hazardous wastes using the EPA F, K, P, and U lists.
4. Define universal wastes and describe the requirements for
handling them.
5. Define the various categories of hazardous waste generators
and explain the regulatory requirements that apply to each.
6. Describe the precautions for the safe handling of hazardous
waste.
7. Identify and explain strategies for waste minimization.
8. Identify the considerations for selecting hazardous waste
transporters and treatment storage and disposal facilities
(TSDF).
9. Discuss the process and options available for the remediation
of contaminated hazardous waste sites.
Reading Assignment
Forward: pp. iv-vii
Chapter 1:
Hazardous Waste
EPA Listed Wastes, 40 CFR 261.31-33: http://www.epa.gov/epa

2. waste/hazard/wastetypes/listed.htm
Unit Lesson
BOS 3125, Hazardous Materials Management
5
(NARA, 2011a)
Here we are, ready to start a course titled “Hazardous Materials
Management,” but the first course unit and first chapter in the
book are titled “Hazardous Waste.” What’s that about? Isn’t
hazardous waste at the end of the lifecycle and more appropriate
for the end of the course? Besides, safety practitioners aren’t
responsible for hazardous waste; that’s an environmental thing,
right?
In order to manage hazardous materials in the workplace
effectively, we need to start with the end in mind; that is, what
happens to the material when we are done with it. The Resource
Conservation and Recovery Act (RCRA) of 1976 introduced us
to the cradle to grave” concept of hazardous materials
management by focusing efforts on the final disposal of
hazardous substances (Haight, 2012). The improper disposal of
industrial waste over many decades had created enormous health
and environmental issues, as well as a nearly insurmountable
cleanup problem.
The Environmental Protection Agency (EPA) has created
regulations for the cleanup of contaminated waste sites, but
more importantly, has forced industries to think about the

3. materials they use, how they are stored and handled, and how
they are to be discarded when no longer needed. The escalating
cost of the disposal of hazardous wastes in accordance with
EPA rules has caused many industries to change to materials
that are less hazardous or change processes so that hazardous
materials are no longer needed. Recycling and reuse of
hazardous materials has become more cost-effective than
disposal. One of the goals of RCRA is to prevent
future problems caused by irresponsible waste management
(Haight, 2012). This goal is being achieved by managing the
full lifecycle of hazardous materials.
Safety practitioners are most often concerned with OSHA
regulations and the effects of hazardous materials on the
workers, and they might feel that compliance with EPA
regulations belongs to someone else. Some organizations do
have a separate environmental compliance office, and other
organizations choose to combine the “safety” and
“environmental” functions. Regardless of how the
responsibilities are divided, the safety practitioner must be
familiar with EPA rules and regulations, since they are central
to the decisions made regarding hazardous materials in the
workplace. Over the years, the OSHA/EPA connection has
become even closer, with OSHA’s Hazardous Waste Operations
and Emergency Response (HAZWOPER) and the Hazard
Communication Standard. It is interesting to note that RCRA
predates both of these OSHA standards.
The core of RCRA is the identification of hazardous wastes.
The first determination is whether or not a material is a solid
waste. Anything that is discarded is considered a solid waste,
but not all solid wastes are hazardous. A solid waste is
designated as hazardous if it is listed in one of the four RCRA
Environmental technicians secure the lid of a hazardous
material container. (Barstow, 2008)

4. hazardous waste code lists (F, K, P, and U). If the material is
not listed, it can still be classified as hazardous
if it exhibits one or more of the criteria of ignitibility,
corrosivity, reactivity, and toxicity. There are really very few
industrial wastes that will not fall into one of the above
categories. (Graphic below is on page 6 of the textbook.)
Producers of hazardous waste are called “generators.”
Hazardous waste generators must determine what category
applies to them: Small quantity generator, large quantity
generator, or conditionally exempt small quantity generator.
The determination requires a comprehensive inventory of all
hazardous materials in use and an understanding of the waste
streams produced. The inventory is often the same one used by
safety practitioners to comply with OSHA standards; again we
see the connection.
Hazardous waste identification process
(Haight, 2012)
Cost-benefit analysis is often used to determine whether
hazardous materials should be replaced with less
Polluted South Platte River, circa 1972
(NARA, 2011b)
hazardous ones, or whether materials can be reused or recycled.
Since ultimate disposal of hazardous materials is subject to a
myriad of regulatory requirements, it is often the most costly
option. At this point, we can see the positive effect on some
additional RCRA goals:
1. Protect human health and the environment

5. 2. Conserve energy and natural resources
3. Reduce the amount of hazardous waste generated
In the 1960s, America found itself awash in hazardous waste.
Lakes and rivers were polluted, and numerous uncontrolled
hazardous waste dumpsites were leaching hazardous substances
into our soil and water supply. The New York Times called
waste “The third pollution” (as cited in U.S. Environmental
Protection Agency, 2002). Perhaps it is more correct to think of
waste, particularly hazardous waste, as the first pollution, since
it is one of the major causes of polluted water, air, and soil.
RCRA was intended to be a pollution prevention solution (U.S.
Environmental Protection Agency, 2002). For the safety
practitioner, it has also aided significantly in injury prevention
by reducing the quantity and types of hazardous material in the
workplace, reducing the risks to all workers.
Role of the States
Under RCRA, hazardous waste management is intended to be a
joint federal/state effort. Using the RCRA framework, each
state creates its own waste management plans to meet its
specific needs and establishes its own regulatory requirements.
This unit will discuss only the Federal RCRA provisions. It is
important that safety and environmental practitioners also
become familiar with all of their state and local hazardous
waste requirements. Most state information can be found on the
Internet.
CERCLA
Safety practitioners also need to be aware of the Comprehensive
Environmental Response, Compensation, and Liability Act
(CERCLA), commonly known as Superfund. Through a tax

6. levied on the chemical and petroleum industries, CERCLA
created a trust fund that is used for cleaning up abandoned or
uncontrolled hazardous waste sites (U.S. Environmental
Protection Agency, 2011). EPA has established a National
Priority List (NPL) for the long-term planning of hazardous
waste cleanup and administers the program through its ten
regional offices.
References
Barstow, T. (2008). USMC-02502 [Photograph]. Retrieved from
http://commons.wikimedia.org/wiki/File:USMC-02502.jpg
Haight, J. M. (Ed.). (2012). Hazardous material management
and hazard communication. Des Plaines, IL: American Society
of Safety Engineers.
U.S. Environmental Protection Agency. (2011) CERCLA
overview. Retrieved from
http://www.epa.gov/superfund/policy/cercla.htm
U.S. Environmental Protection Agency. (2002). 25 years of
RCRA: Building on our past to protect our future [Brochure].
Washington, D.C.: Author. Retrieved from
http://www.epa.gov/osw/inforesources/pubs/k02027.pdf
U.S. National Archives and Records Administration (NARA).
(2011a) Special precautions must be taken for disposing of
hazardous materials. As in this area near El Centro in the…-
NARA [Photograph]. Retrieved from
http://commons.wikimedia.org/wiki/File:SPECIAL_
PRECAUTIONS_ MUST_BE_TAKEN_FOR_DISPOSING_OF_
HAZARDOUS_
MATERIALS._AS_IN_THIS_AREA_NEAR_EL_CENTRO_IN_
THE..._-_NARA_-_553905.jpg

7. U.S. National Archives and Records Administration (NARA).
(2011b) The polluted South Platte River- NARA [Photograph].
Retrieved from
http://commons.wikimedia.org/wiki/File:THE_POLLUTED_SO
UTH_ PLATTE_RIVER_-_NARA_-_544810.tif
Suggested Reading
Learn more about this unit’s topics by researching in the CSU
Online Library. The following are examples of the information
you can find in the Academic OneFile database of the CSU
Online Library:
· “EPA Reports on Progress Made Toward the 2020 RCRA
Corrective Action Goal,” an article in the September-October
2012 issue of the Hazardous Waste Consultant, discusses RCRA
Subtitle C, which provides a system for managing hazardous
waste from cradle to grave, and EPA’s strategy for enforcing
this type of waste management. The article provides information
on EPA regional office corrective action contacts and facilities,
as well as discussion of such topics as enforceable mechanisms
and assessing, targeting, and prioritizing facilities for
enforcement.
· “RCRA Nonhazardous Solid Waste Identification Rule,” from
the March-April 2013 issue of Hazardous Waste Consultant,
discusses the final rule issued by the EPA on March 21, 2011,
concerning nonhazardous secondary materials that may or may
not be RCRA solid wastes when burned in combustion units and
the Feb. 27, 2013 revisions that clarify that 2011 ruling. The
discussion goes back to the first ruling on the subject in 2000,
and carries forward to the current 2013 clarification.
· “Delhi’s Dumps Are ‘Public Health Time Bombs’,” by Wendy
Glauser, is a May 2013 article that talks about the landfills in
India and how advances in waste management have negatively
impacted those who depend on scavenging in order to earn
money, such as 11-year-old Ambiya.

8. · “Canadian Zinc Producer Liable for Hazardous Discharges
into the United States,” an article in the March-April 2013 issue
of Hazardous Waste Consultant, details a December 14, 2012
decision against a Canadian zinc producer that addressed illegal
discharges of slag and effluent that had been occurring for more
than 60 years, and the resultant costs for the company. This is
only the first phase of the case.
· Health care wastes are hazardous, and they occur all over the
world. “Assessment of the Health Care Waste Generation Rates
And its Management System in Hospitals of Addis Ababa,
Ethiopia, 2011” is a January 12, 2013, article in BMC Public
Health that discusses health care waste generation rates, waste
classification, unsanitary landfill sites, and the disposal
mechanisms used for the health care waste, using information
collected from six hospitals in Addis Ababa, Ethiopia.
The following are examples of articles you can find in the
GreenFILE database of the CSU Online Library:
· “EPA Memos Provide Agency Interpretations of RCRA
Requirements,” is a 2012 article from the Hazardous Waste
Consultant. The article discusses the EPA position on a variety
of RCRA topics that were addressed in regulatory interpretation
memos. The memos are presenting in Q&A format.
· “Developing Best Management Practices,” by Norman Wei,
discusses best management practices (BMPs) required under
EPA regulations. Topics discussed include properly written and
documented BMPs. This article appeared in the April 2013 issue
of Pollution Engineering.
· “Power Player,” by Allan Gerlat, discusses breakthrough
projects undertaken by Pennsylvania’s Lancaster County Solid
Waste Management Authority to derive resources from waste,
such as a wind power generation project and another in which
LCSWMA will provide steam for processing needs for a
soybean crushing facility. The article appeared in the March
2013 issue of Waste Age.

9. Learning Online
You can also find a wealth of information concerning hazardous
waste by searching online. Be wary when looking online,
however, as all of the information available via the Web is not
accurate and reliable. The following are examples of
trustworthy web sites that pertain to this unit and its topics:
· EPA Non-Hazardous Waste Regulations
http://www.epa.gov/osw/laws-regs/regs-non-haz.htm
· EPA Hazardous Waste Regulations
http://www.epa.gov/osw/laws-regs/regs-haz.htm
· Use of Risk-Based Decision-Making in UST Corrective Action
http://www.epa.gov/swerust1/directiv/od961017.htm
· U.S. Environmental Protection Agency. (2002). 25 years of
RCRA: Building on our past to protect our future [Brochure].
Washington, D.C.: Author. Retrieved from
http://www.epa.gov/osw/inforesources/pubs/k02027.pdf
· RCRA History
http://www.epa.gov/osw/laws-regs/rcrahistory.htm
· RCRA Guidance, Policy, and Resources
http://www.epa.gov/osw/laws-regs/rcraguidance.htm
Learning Activities (Non-Graded)
State and Local Regulations vs. EPA: Who’s Tougher?
Research the hazardous waste regulations established by your
state and local area. Are they more restrictive than the EPA
requirements? Create a table that highlights the major
differences.

10. Workplace Waste Generation
Find out what hazardous waste is generated by the organization
for which you currently work. Determine the classification of
hazardous waste generator you think would apply and compare
your decision to how the organization classifies itself. If there
is a difference, what caused it?
What’s In The House?
Create an inventory of cleaning products on hand in your home.
Based on the major ingredients listed on the label, determine if
each product would be a hazardous waste (if you were a
regulated generator). Use the EPA definitions of characteristic
wastes and the listed wastes (F, K, P, & U) in 40 CFR 261 to
make your determinations.
Non-graded Learning Activities are provided to aid students in
their course of study. You do not have to submit them. If you
have questions, contact your instructor for further guidance and
information.
Key Terms
1. Characteristic waste
2. Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA)
3. Conditionally exempt small quantity generator
4. Corrosivity
5. Emergency Planning and Right to Know Act (EPCRA)
6. Ignitibility
7. Large quantity generator
8. Listed waste
9. Reactivity
10. Resource Conservation and Recovery Act (RCRA)
11. Small quantity generator

11. 12. Superfund Amendment and Reauthorization (SARA)
13. Toxicity
14. Treatment, storage and disposal facility (TSDF)