Everyday Hazmat User's Training Guide
Section III Hazardous Materials Management (continued)
The Transition to Hazardous Waste
When Does a Product Become a Waste
A product becomes a waste when you decide it is no longer useful, it does not meet its original specifications and is not usable, or its shelf life has been exceeded for so long that it probably will not perform satisfactorily.
Find a Use Before Declaring a Product a Waste!
If you no longer need a product, the best approach is to find another use for it. If the product is paint, use it as an undercoating. Consider transferring the product to another USDA Forest Service unit. The more you can use up, the less you will have to deal with as a hazardous waste.
When a Product Becomes a Hazardous Waste
If products cannot be used or transferred, or if they no longer meet specifications or their shelf life has been seriously exceeded, you must declare them hazardous wastes and move them to your hazardous waste accumulation area. First, make sure the product has a proper manufacturer’s label. Notify your hazardous waste coordinator when you move wastes to the hazardous waste accumulation area.
All containers of hazardous waste must be labeled as a hazardous waste:
- The date
you declared the product a hazardous waste must be marked on
the label.
- The marked container must be moved to the hazardous waste accumulation
area.
- The amount of hazardous waste moved to the accumulation area must be
added to the area log.
- The hazardous waste, along with all other hazardous wastes, must be inspected routinely and disposal arrangements must be made before the allowable storage time onsite has expired.
What is a Hazardous Waste?
Hazardous wastes are any product wastes that:
- Have a flashpoint lower than
140°F
- Have a pH lower than 2.5 or higher than 12.5
- Are reactive
- Fail the
TCLP (Toxicity Characteristic Leaching Procedure) test, making it a
toxic waste
- Contain a chemical listed by the EPA
Refer to the Hazardous Wastes guideline.
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If a product that becomes a waste no longer has the manufacturer’s label (or the equivalent), and you can’t positively establish what it is, you have to treat the waste as an unknown. See the Unknown Wastes guideline.
When products become wastes, be sure to keep them separated, just as you would keep incompatible products separated.
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