Waste Characterization Regulations: A Guide to Compliance with the RCRA

For any company operating in the United States that generates waste, it is essential to comply with the Resource Conservation and Recovery Act (RCRA) regulations. 

21 JUL 2023 ALS

What is RCRA Compliance?

RCRA compliance is the process of ensuring that facilities and individuals that generate, transport, treat, store, or dispose of hazardous waste are in compliance with the Resource Conservation and Recovery Act (RCRA).

The Resource Conservation and Recovery Act (RCRA), created by the US EPA in 1976, establishes regulations that define how hazardous and non-hazardous waste is handled, transported, recycled, and managed.

This article offers valuable information on waste characterization compliance, the importance of testing, and how ALS can help you stay compliant with RCRA regulations. Understanding the requirements and appropriate testing methods is crucial for proper waste management and cost control.


Table of Contents:

  1. What is Waste Characterization Compliance?
  2. RCRA Hazardous Waste Identification
  3. Testing Procedures and RCRA Classification Codes
  4. Why is Accurate Waste Classification Important?
  5. ALS Waste Testing Services
  6. What is the TCLP Method?
  7. What is the SPLP Method?
  8. Get RCRA Compliant Today


What is Waste Characterization Compliance?

Waste Characterization Compliance is the applicable storage, treatment, handling, transportation, and disposal of waste, according to RCRA guidelines. Under the RCRA (40 CFR Subpart 261), companies are required to determine if their waste is hazardous.

Hazardous waste is identified by testing and classified according to RCRA hazardous waste codes. It must be handled, stored, treated, and transported in accordance with EPA guidelines.

Testing methods, such as the toxicity characteristic leaching procedure (TCLP), waste composition analysis, and waste characterization techniques, play an essential role in identifying RCRA waste codes and classifying waste properly. By utilizing waste testing labs near you and following an effective waste sampling and analysis plan, companies can help ensure accurate waste stream testing and RCRA waste generator compliance.

With proper waste testing services, waste management regulations can be adhered to, ensuring that hazardous waste testing and solid waste testing are performed correctly, and waste disposal regulations are maintained.


RCRA Hazardous Waste Identification:

  • Hazardous wastes are categorized as listed waste or characteristic waste.
  • Listed wastes are classified into F, K, P, and U lists in Title 40 of the Code of Federal Regulations (CFR), Subpart 261.
    • F-list: Wastes from non-specific sources, including solvent wastes, metal finishing wastes, dioxin-bearing wastes, and more.
    • K-list: Hazardous wastes from specific sectors such as wood preservation, organic chemicals manufacturing, petroleum refining, and others.
    • P-list: Acute hazardous wastes from discarded commercial chemical products.
    • U-list: Hazardous wastes from discarded commercial chemical products.
  • Hazard Codes (T, H, I, C, R, E) are assigned to listed wastes to indicate the reasons for their listing:
    • T for Toxicity
    • H for Acute hazards
    • I for Ignitability
    • C for Corrosivity
    • R for Reactivity
    • E for Extraction procedure toxicity
  • Characteristic wastes exhibit properties of ignitability, corrosivity, reactivity, or toxicity.
  • The method's focus on wastewater and its limitations with aqueous samples containing high solids may pose challenges for some users.
  • Handling, storage, and processing requirements specified in Draft Method 1633 may increase the time and expense required for analysis.


Testing Procedures and RCRA Waste Classification Codes

The table below provides a list of testing procedures and RCRA waste classification codes:

Testing Procedure Classification Codes
TCLP Volatile Organic Compounds (1311/8260) Identification and classification of F-listed wastes
TCLP Semi-volatile Organic Compounds (1311/8270) Classification of K-listed wastes
TCLP Pesticides (1311/8081) Classification of P-listed wastes (acutely hazardous)
TCLP Herbicides (1311/8151) Classification of U-listed wastes (hazardous)
TCLP RCRA 8 Metals (1311/6010 or 6020/7470) Identification and quantification of metals in F, K, P, and U lists
State-specific Total Petroleum Hydrocarbons (TPH) Characterization and classification of petroleum-based wastes
Reactive Cyanide (SW Classification of wastes containing cyanide
Reactive Sulfide (SW Classification of wastes containing sulfide
Ignitability (SW 1030) Classification of wastes with flammable properties
Corrosivity (SW 9045D) Classification of wastes with corrosive properties
Total Organic Halides (TOX) (SW 846 Method 9020B) Identification and quantification of organic halides in wastes
Hexavalent Chromium (SW 846 Method 7196) Classification of wastes containing hexavalent chromium
Paint Filter (EPA 9095B) Waste characterization and labeling based on free liquid content
pH (SM 4500/EPA 9045) Waste characterization and labeling based on acidity/alkalinity


Why is Accurate Waste Classification Important?

Accurate waste classification serves two primary purposes:

  1. Compliance with RCRA Legislation: Proper waste management is essential to comply with RCRA regulations. By accurately classifying waste, you ensure that it is handled and disposed of in accordance with legal requirements.
  2. Cost Control: Misclassifying waste as hazardous when it is not can lead to unnecessary costs.

Accurate waste characterization helps you avoid unnecessary expenses associated with incorrect handling and disposal procedures.


ALS Waste Testing Services

ALS provides comprehensive waste characterization services to help companies classify their waste accurately and ensure compliance with RCRA regulations. Our testing methods cover various waste parameters, including:

  • TCLP Volatile Organic Compounds (1311/8260)
  • TCLP Semi-volatile Organic Compounds (1311/8270)
  • TCLP Pesticides (1311/8081)
  • TCLP Herbicides (1311/8151)
  • TCLP RCRA 8 Metals (1311/6010 or 6020/7470)
  • State-specific Total Petroleum Hydrocarbons (TPH) methods
  • Reactive Cyanide (SW
  • Reactive Sulfide (SW
  • Ignitability (SW 1030)
  • Corrosivity (SW 9045D)
  • Total Organic Halides (TOX) (SW 846 Method 9020B)
  • Hexavalent Chromium (SW 846 Method 7196)
  • Paint Filter (EPA 9095B)
  • pH (SM 4500/EPA9045)


What is the TCLP Method?

Toxicity Characterization Leaching Procedure (TCLP) is a crucial method used for waste characterization, specifically designed to assess the leaching potential and mobility of organic and inorganic analytes in various types of wastes. Here's an overview of the TCLP process:

  • Liquid Waste Filtration: Liquid waste samples undergo a preliminary filtration step using a glass fiber filter to remove solids before analysis.
  • Solid Waste Extraction: Solid waste samples require the removal of any liquid phase before extraction. The extraction is performed using a specific fluid selected based on the alkalinity of the waste. The sample is rotated for approximately 18 hours to facilitate analyte leaching.
  • Analysis of Extracted Liquid Phase: The resulting liquid phase from the extraction process is thoroughly analyzed, similar to liquid waste samples. This analysis provides valuable information about leaching potential and the presence of hazardous substances.

By implementing the Toxicity Characterization Leaching Procedure (TCLP), waste management professionals can effectively evaluate the leaching potential and mobility of analytes in different waste types. The procedure involves liquid waste filtration, solid waste extraction, and analysis of the extracted liquid phase. Understanding TCLP is crucial for waste characterization and regulatory compliance efforts.


What is the SPLP Method?

Synthetic Precipitation Leaching Procedure (SPLP) is another important method for estimating the mobility of target compounds in waste exposed to rainfall (SW 846 Method 1312). Here's an overview of the SPLP process:

  • Treatment of Liquid Samples: Liquid samples in the SPLP procedure are treated in the same manner as outlined in Method 1311.
  • Extraction of Solid Waste: For solid waste samples, any liquid phase present within the waste is removed prior to extraction. The extraction process involves the use of a specific fluid, depending on whether the sample is soil (based on the region of the country) or waste (using a pH 4.2 solution). The sample is then rotated in a designated vessel for approximately 18 hours to facilitate leaching.
  • Analysis of the Extracted Liquid Phase: Similar to the analysis of liquid waste samples, the SPLP method entails conducting analysis on the liquid phase extracted from the sample. This analysis provides insights into the presence and mobility of target compounds.


Get RCRA Compliant Today

Understanding waste characterization compliance and the appropriate testing methods is crucial for companies dealing with waste. By partnering with ALS, you can ensure accurate waste classification, proper management, and compliance with RCRA regulations. Avoid unnecessary costs and maintain environmental responsibility by prioritizing waste characterization testing.

For detailed federal regulations on TCLP, refer to this resource: https://www.ecfr.gov/cgi-bin/text-idx?node=se40.26.261_124&rgn=div8

Accurate waste characterization is key to protecting the environment, complying with regulations, and optimizing your waste management practices. Contact ALS today to learn more about our waste testing services and ensure compliance with RCRA regulations.