Ignitable Hazardous Waste Characterization Being Updated by EPA

EPA has proposed a modernization of the ignitable hazardous waste characterization under the definition of D001 ignitable hazardous waste. The update published on April 2, 2019 (Federal Register Vol. 84, No. 63) will address four major areas by:

  • Incorporating modern consensus standards into the regulations;

  • Allowing for the use of non-mercury thermometers in the characterization process;

  • Narrowing the aqueous solution exclusion; and

  • Clarifying the testing requirements for multi-phase materials.

First EPA will update the referenced flash point testing methods by adding ASTM Standard D8175-18 and ASTM Standard D8174-18 along with the incorporation by reference to allow future updates to occur without regulatory changes. Generator knowledge will continue to be acceptable in place of one of the listed methods.

When the original regulations were developed between 1978-1980, mercury thermometers were the best option on the market for accurate measurement of temperatures. Given the current EPA emphasis on phasing out the use of mercury wherever possible due to the risk of release into the environment, EPA will begin allowing safer, technically appropriate, readily available non-mercury temperature measurement devices if this proposal is finalized.

EPA will officially utilize the DOT definition of the alcohol exclusion as w