• The Safety Data Sheet (SDS) is authorized and required to be used by OSHA, the Occupational Health and Safety Administration.  While its information can be useful, it is not authorized by the USEPA.  Specifically, sections 1 through 11 and 16 of the SDS are authorized and required by OSHA.  Sections 12 through 15 – including section 13 Disposal Considerations  – is not authorized or required by OSHA.  Information in these unauthorized sections of the SDS is provided voluntarily the manufacturer and may not be relied upon for compliance.
• The generator of a waste must determine if a waste is hazardous and then manage it properly from “cradle-to-grave.”
• Based on the information on the SDS for the product Metals Prep Set Reagent B it is 100% Potassium persulfate and an oxidizer.  If it retains the characteristic of an oxidizer at its point of generation as a waste, i.e. when you discard it, then it will be a hazardous waste for the characteristic of Ignitability (D001).
• Based on the information on the SDS for the product Lead TNT Reagent Vial it contains 60-70% potassium cyanide which is a p-listed material.  It may be a p-listed hazardous waste if it is disposed of unused.  If it is used then the P-code will not apply.  It is also possible – but unlikely – that it could also be a hazardous waste for the characteristic of Reactivity (D003) if it emits cyanide gas at toxic levels.

Summary:

While the SDS can be a good source of information, it is not the final word on the determination of whether or not a waste is hazardous.  It is important to note that the SDS describes an unused product and may not be an accurate description of that product when it becomes a waste.

The responsibility for the hazardous waste determination is solely the generator’s.

I hope this helps.

Please don’t hesitate to contact me with any questions or if you require HazMat Employee Training or Hazardous Waste Personnel Training.