Waste Designation Decision Matrix - Toxicity Determination
This matrix is provided as an assistance tool. It cannot be used as a substitute for following applicable city, state, and federal laws.
|Does the waste exhibit toxicity characteristics based on the results of a Toxicity Characteristic Leachate Procedure test?|
Testing for Toxicity Characteristics (TC)
As a generator, it is YOUR responsibility to designate your own waste as hazardous or not. When it comes to D004-D043 characteristics, it is often easy to eliminate all or most of the characteristics just by reviewing the toxic constituents. Since there are only 40 of them, you should ALWAYS peruse the list of TC constituents.
A test called the Toxicity Characteristic Leachate Procedure (TCLP) is used to determine if a waste is characteristically hazardous. This is a fairly expensive test that an analytical laboratory can perform for you. Essentially, the test simulates the conditions that the waste would be placed under if it was in a landfill. If the resulting leachate has a level of one of the hazardous constituents that is considered "toxic" by EPA, the waste is hazardous.
Testing can prove without much doubt if you have leachable levels of cadmium (D005) or lead (D008). However, why test an aqueous solution of acids that you no reason to believe ever came into contact with any heavy metals? This is where "using process knowledge" can save you some money in laboratory testing.
So, when deciding whether or not to test for TC constituents, ask yourself the question: "Do I have ANY reason to believe that ANY of the forty TC constituents are in my waste?" If the answer is no, feel comfortable not testing. If not, you may wish to at least eliminate some of them on the list to minimize testing costs.