Daniels Training Services

Q&A: Determination of Hazardous Waste Generation for the Characteristic of Toxicity

Q&A: Determination of Hazardous Waste Generation for the Characteristic of Toxicity

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

http://www.danielstraining.com/

A question to my website on April 29, 2016:

My question is: If your waste is considered a haz waste due to one chemical determined by the TCLP process. Do we count the weight of the chemical in the waste or the total weight of the waste that determines how much you generate. Thanks.

My reply later that same day:

If a representative sample of a waste is analyzed by TCLP and determined to have a leachable toxin above the regulatory threshold, then the entire waste from which the representative sample was derived is assigned the applicable hazardous waste code.  Therefore, the entire weight of the waste – not just the weight of the toxin in the waste – is used for the purpose of determining hazardous waste generation and the hazardous waste generator status.

I hope this helps.
Please don’t hesitate to contact me with any other questions.