Determining a Class 8 Corrosive Material and a D002 Corrosive Hazardous Waste From the SDS

Question to me (3.19.15) from a customer who had recently attended one of my TRAINING SEMINARS:

Dan,

I have a waste that is liquid but has no pH because it is not water-based. The SDS says it is DOT Class 8 so that means it must corrode steel at >0.25 inches/ year. RCRA has a similar criteria, but are DOT and RCRA referring to the same test standard? If yes, then I clearly have a hazardous waste. Let me know.

Thanks,

My reply, later that same day:

The EPA definition of the hazardous characteristic for corrosivity (40 CFR 216.22) is an aqueous solution with a pH of 2 or less or 12.5 or greater or…

(2) It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55 °C (130 °F) as determined by Method 1110A in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846, and as incorporated by reference in §260.11 of this chapter.

The DOT definition of Class 8 Corrosive includes a material that causes full thickness destruction of human skin at site of contact within a specified time period and…

A liquid, or a solid which may become liquid during transportation, that has a severe corrosion rate on steel or aluminum based on the criteria in §173.137(c)(2).

173.137(c)(2) indicates a corrosive material exhibits…

a corrosion on either steel or aluminum surfaces exceeding 6.25 mm (0.25 inch) a year at a test temperature of 55 °C (130 °F) when tested on both materials. The corrosion may be determined in accordance with the UN Manual of Tests and Criteria (IBR, see §171.7 of this subchapter) or other equivalent test methods.

I suggest you contact the supplier from the SDS to determine what test method they used. If it is not SW-846 (note the “or other equivalent test method” in 173.137(c)(2)) it may be similar enough to yield the same result. Also, once you determine the method the supplier used you may wish to contact a lab that performs both of the analysis types to see if there is a difference.

I hope this helps.

Dan

Customers quick reply (still 3.19.15):

Dan, Thanks. I’ll call my supplier & test lab.

I’m curious, so on 3.20.15 I write:

Please let me know what you learn from the lab.

Last correspondence on 3.20.15:

My lab only does ASTM 1110A.

Conclusion:

The test method performed by my customer’s lab (ASTM 1110A) is acceptable for purposes of determining the USEPA’s characteristic for corrosivity as that is referenced specifically at 40 CFR 261.22. It may also be acceptable for determining if it is a Class 8 Corrosive Material as defined in the PHMSA/USDOT regulations even though it is not specifically referenced at 173.137(c)(2). The inclusion of the language, “…or other equivalent test methods.” may be interpreted to include ASTM 1110A as acceptable.

A note of warning: my customers reference to section 14 of the SDS is worth a warning:

The SDS says it is DOT Class 8 so that means it must corrode steel at >0.25 inches/ year.

The information in the SDS (and the old MSDS, for that matter) is not authorized by PHMSA/USDOT for purposes of compliance with the Hazardous Material Regulations. Therefore, any information on an SDS/MSDS that purports to provide PHMSA/USDOT regulatory information should be taken as guidance only and not be relied on solely for the purposes of determining compliance.