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Waste generators are responsible for characterizing their waste. They can do this by testing (waste analysis) or by applying knowledge of the waste. The tests that are allowed are described in the regulations.

If you are a generator, you can use knowledge of the process used to generate the waste or “common knowledge” to determine that the waste is a hazardous waste. For instance, it is common knowledge that gasoline is ignitable.

Generators must keep records of all waste determinations, including any test results, waste analyses, or other documentation.

All waste must be considered hazardous until proven otherwise.

Waste characteristics

There are four basic waste characteristics you need to be aware of. For transportation proper shipping names, characteristic wastes are “D” wastes.

1. Ignitability (I): Ignitable wastes can create fires under certain conditions. Any waste material that, after testing, exhibits the characteristic if ignitability, but is not a listed waste, is assigned the EPA Hazardous Waste Number D001.

2. Corrosivity (C):Corrosive wastes are acids or bases that are capable of corroding metal containers, such as storage tanks, drums, and barrels. Any waste material that, after testing, exhibits the characteristic of corrosivity, but is not a listed waste, is assigned the EPA Hazardous Waste Number D002.

3. Reactivity (R): Reactive wastes are unstable under “normal” conditions, and can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water. Any waste material that, after testing, exhibits the characteristic if reactivity, but is not a listed waste, is assigned the EPA Hazardous Waste Number D003.

4. Toxicity (E): Toxic wastes are harmful or fatal when ingested or absorbed, such as poisons. When toxic wastes are land disposed, contaminated liquid may leach from the waste and pollute ground water. Any waste material that, after testing, exhibits the characteristic if toxicity, but is not a listed waste, is assigned the EPA Hazardous Waste Number D004 – D043. The number will correspond to the identified toxic contaminant. The numbers and contaminants are found in 40 CFR 261.24.

Your employer's responsibility

Your employer is responsible for making sure you are aware or have general knowledge of each waste characteristic. If you work with or around hazardous waste, your employer is also responsible for making sure you understand hazards associated with your work.

HANDOUT: Outdoor Construction