The characteristic of reactivity [40 CFR 261.23] is not just one characteristic; it’s a grouping of eight different properties and none of them have an empirical means of measurement. Subjectively, however, they are similar to the classification criteria under other regulations such as the DOT’s hazardous materials rules and the Global Harmonization System.
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8 Ways to Be Reactive Hazardous Waste
From a regulatory perspective, there are eight ways a solid waste can be identified as a D003 reactivity hazardous waste. If a representative sample of your waste has any of the following properties, then it exhibits the reactivity characteristic:
(1) It is normally unstable and readily undergoes violent change without detonating.
(2) It reacts violently with water.
(3) It forms potentially explosive mixtures with water.
(4) When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.
(5) It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.
(6) It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.
(7) It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.
(8) It is a forbidden explosive as defined in 49 CFR 173.54, or is a Division 1.1, 1.2 or 1.3 explosive as defined in the DOT’s regulations at 49 CFR 173.50 and 173.53.
These eight categories include materials that are hazardous when they react to heat, pressure, friction, or shock, or when they contact air or water.
The Challenge: No Test Methods!
Here’s the big challenge with identifying the characteristic of reactivity: there are no standardized SW-846 test methods to make a hazardous waste determination! (At one time there were empirical standards for certain levels of cyanide or sulfide bearing wastes, but the EPA withdrew that guidance in 1998.) It’s up to you to use “generator’s knowledge” to determine if your waste meets any of the stated criteria.
The following hints may lead you to determine your waste is reactive:
The GHS Exploding Bomb Pictogram
Look out for Safety Data Sheets and GHS labels featuring the “exploding bomb” pictogram on your raw materials. If this warning is associated with the materials that make up your waste, there is a chance your waste meets the RCRA reactivity characteristic.
Under OSHA's Globally Harmonized System of Classifying and Labeling Chemicals (GHS), the "exploding bomb" pictogram is used to alert professionals to explosives, self-reactives, and organic peroxides.
The DOT Explosives Label or Placard
Secondly, a DOT hazard label or placard will indicate if you’re handling a Division 1.1 mass explosion hazard, 1.2 projection hazard, or 1.3 fire or minor projection hazard.
If you see a Class 1 label or placard, there is a good chance you are dealing with a material that meets the RCRA reactivity characteristic.
If you have a chemistry background, the table below may be helpful. Explosive properties are commonly associated with certain chemical groups that react and cause rapid increases in temperature or pressure.
Over-classification of Reactive Wastes
If you suspect your waste is a reactivity material but are unsure, it is acceptable to “overclassify” it as a D003. In the preamble to Generator Improvement Rule (GIR), which took effect on May 30, 2017, EPA includes language to support this assertion:
“Even if the waste may not be hazardous, ‘over managing’ the waste is acceptable and meets the requirements of 262.11 because the generator has made a determination intended to ensure beyond a doubt, proper and protective management of the waste within the RCRA program.”
[FR Vol 81, No. 228, Monday Nov 28, 2016, p. 85750]
The DOT Hazardous Materials Regulations (HMR) cover off-site shipments of hazardous waste. It is generally illegal to overclassify a hazardous material. An exception to this rule, however, is for hazardous waste that may be assigned a proper shipping name, hazard class, identification number and packing group based on the shipper’s tentative determination. [See 49 CFR 172.101(c)(11)]
Therefore, you may err on the side of caution when shipping these wastes to ensure that supply chain personnel understand the risks associated with your waste.
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