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This Fact File provides tips for using safety data sheets (SDSs) to support your hazardous waste determinations. Some wastes have their own corresponding SDSs, but more often, SDSs are used to support hazardous waste classifications by identifying ingredients used in the process generating the waste. While SDSs might not represent the waste characteristics themselves, they may be useful in identifying possible hazardous constituents and their properties.
Hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA) from “cradle to grave,” meaning from the time the waste is generated until it is finally disposed of. The critically important first step in hazardous waste management is determining if you have a hazardous waste. Waste determination is also called waste identification or waste characterization. In order to be a hazardous waste, the waste must be:
You can use information from a variety of sources to make these determinations. You may choose to characterize the waste yourself, hire a consultant, use the services of a waste disposal company, or a combination of these three. If you are making some or all of your waste determinations yourself, the SDSs for any hazardous chemicals used in your operational processes may be able to help.
Chemical manufacturers or importers must create or obtain an SDS for each hazardous chemical that they produce or import, and they must provide an SDS at no cost to the downstream users of the hazardous chemical. Section 13 of an SDS covers disposal considerations and may help you make a waste determination — however, section 13 is non-mandatory, so it may not appear on all SDSs. There are other ways to use the information on an SDS to make hazardous waste determinations, though, and here are some tips to help.
The first two essential steps when using a SDS to support hazardous waste determinations are:
You should not use a SDS for waste determination purposes in the following circumstances:
40 CFR 261 – Identification and Listing of Hazardous Waste
29 CFR 1910.1200(g) and Appendix D – Hazard communication: Safety data sheets
“Safety data sheet (SDS)” means written or printed material concerning a hazardous chemical that meets the Occupational Safety and Health Administration’s (OSHA) requirements found at 1910.1200(g). The SDS, formerly known as a material safety data sheet (MSDS), must include the section numbers and headings found in paragraph (g).
“Hazardous waste” means waste with properties that make it dangerous or capable of having a harmful effect on human health and the environment. Under the Resource Conservation and Recovery Act (RCRA), hazardous wastes are specifically defined as wastes that meet a particular listing description or that exhibit a characteristic of hazardous waste (ignitability, corrosivity, reactivity, and toxicity).
Waste determination (also known as waste identification or waste characterization) is a critically important first step of every hazardous waste management program. The information contained in safety data sheets (SDSs) can be a helpful asset in supporting these determinations.
A new employee for an automotive repair shop suggests the shop switch to a new degreaser than the one they currently stock. The mechanic believes the new degreaser, one used at a previous job, is much stronger and would save time on each job. The shop supervisor likes the idea of saving time, but wants to make sure the new material won’t change anything related to their waste disposal.
So, the supervisor starts by looking at the SDS for the new product. The supervisor sees that the product has methylene chloride listed as 25% of the product ingredients. Comparing these ingredients to the waste characterization sheet the supervisor recently received at a training session, the supervisorfinds that degreasers containing methylene chloride cause the waste to be classified with an F001 waste code, something they currently don’t have for their waste profile. After this discovery, the supervisor tells the crew that they are not going to change to the new degreaser. The supervisor explains that the stronger chemical, methylene chloride, works fast and would save time but would be more hazardous for them and would cost more money for disposal — in the end, those risks aren’t worth the time savings.