What Is Acute Hazardous Waste?

Table of Contents

• What Is an Acute Hazardous Waste?
• Acute Hazardous Waste List
• How Do You Read the P-list and F-list Tables?
• What Is the Difference Between Acute Hazardous Waste and Hazardous Waste?
• Why Is It Important to Recognize Acute Hazardous Waste?
• Learn More About Acute Hazardous Waste From Hazmat School

It is crucial to understand the different types of waste if you handle hazardous waste, whether through use, transportation, storage, management or disposal. Acute and non-acute hazardous waste require different safety and compliance protocols, making it necessary for individuals and employers to learn about their legal and regulatory requirements.

This article is the first step to learning what acute hazardous waste is, how they are listed and how they differ from other types of hazardous wastes. You will also know why it is essential to differentiate acute hazardous wastes from non-hazardous ones.

What Is an Acute Hazardous Waste?

Hazardous waste can be defined as waste that is fatal to humans in low doses. Where there is no data regarding human toxicity, there are criteria for designating waste as acutely hazardous. These include:

1. A dermal lethal dose 50 toxicity (rabbit) below 200 milligrams per kilogram or can cause or significantly contribute to an increase in incapacitating reversible or severe irreversible illness.
2. An oral lethal dose 50 toxicity (rat) below 50 milligrams per kilogram.
3. An inhalation lethal concentration 50 toxicity (rat) below 2 milligrams per liter.

Acute and extremely hazardous waste presents specific health and safety risks, subjecting them to rigorous accumulation limits and on-site generation. The Resource Conservation and Recovery Act (RCRA) standards regulate acute hazardous more stringently than regular hazardous wastes that are only toxic, reactive, ignitable and corrosive because they can cause death, serious illness or disabling personal injury when they come in minimal contact with humans.

Acute Hazardous Waste List

Acute hazardous waste may be listed in one of two places in the regulations. First is all unused, discarded commercial chemical products on the P-list at part 261.33(e) of the statute, and formulations and mixtures with the chemical as a sole active ingredient. We’ll discuss this in detail subsequently. The second list relates to the used and spent process waste indicated and identified with a hazard code “H” on the F-list at 40 Code of Federal Regulations (CFR) 261.31

Wastes may be evaluated as not part of the P-list but may still be hazardous because they display a characteristic or appear on a different list. Therefore, it helps to assume that a waste is hazardous and manage it as such until a final evaluation confirms it as non-hazardous under all the applicable lists and characteristics.

Waste regulated under the P-list are those disposed of as unused for the intended purpose. Dilution or other product preparation for use is disregarded as being used for the intended purpose. If sodium azide-based pesticide is discarded before use, it would be P-listed as acute hazardous waste, even if it is diluted or otherwise prepared for use. However, overspray from a crop duster aircraft after a flight, since overspray is waste resulting from the pesticide’s use, is no longer a P-listed waste.

As earlier indicated, the regulated P-list wastes have the chemical as the sole active ingredient. But what is an active ingredient? Active ingredients are those that perform the product’s primary function regardless of the concentration level of those ingredients. Ingredients used as solvents, preservatives, stabilizers and adjuncts are non-active unless that is the product’s function.

For example, some broad-spectrum pesticides have sodium azide as their sole active ingredient. Such pesticides would be P-listed acute hazardous wastes. On the other hand, the airbags in some motor vehicles use sodium azide as a propellant and ferric oxide as an oxidizing agent. These activators would not be P-listed when discarded before use because sodium azide is not the sole ingredient.

How Do You Read the P-list and F-list Tables?

There are five critical elements to consider when reading the P-list table. The acute hazardous F-list table omits the chemical abstract service (CAS) registry number because each of the waste may include other chemical compounds. Each of the elements plays an important role:

1. Hazardous waste number: The four-character waste code used for the annual reporting of your site’s hazardous waste generation.
2. CAS registry number: The unique number assigned to individual chemical compounds to help distinguish them from similar compounds that may possess different physical properties or closely related generic or common names.
3. Generic listed name: The names of the chemical compounds in the P-list are alphabetically arranged. Chemical compounds may, however, have different names, and only one may be P-listed.
4. Hazard code: There are three different capital letters — H, T and R — each indicating a reason for listing a chemical compound. Hazard code “H” represents acutely toxic, “R” represents reactive and “T” represents toxic substances.
5. Notes: The additional information is specific to each listed chemical compound. They may include definitions and potential exemptions.

What Is the Difference Between Acute Hazardous Waste and Hazardous Waste?

There are several differences between acute and non-acute hazardous wastes, including the following:

• Acute hazardous wastes substantially threaten human health and the environment when improperly treated, stored, transported, disposed of or otherwise managed. They are more dangerous than other types of hazardous waste.
• Acute hazardous wastes are regulated more stringently than ordinary hazardous waste.
• Acute hazardous wastes use hazard code “H” and include almost all forms of dioxin-bearing waste.
• Acute hazardous wastes typically come from discarded commercial products.

Why Is It Important to Recognize Acute Hazardous Waste?

First, knowing the difference between acute and non-acute hazardous wastes is essential for ensuring the safety of your employees because it helps them understand how to handle the waste product. The same applies to anyone who comes into contact with the material.

Second, understanding the differences is vital for compliance. For example, site RCRA generators count acute hazardous waste separately from non-acute dangerous waste. If your facility generates more than 2.2 pounds or 1 kilogram of acute hazardous waste within a calendar month, then the site is a large quantity generator (LQG). The implication is that you must comply with the LQG requirements under 40 CFR 262.17.

The satellite rules for small and large quantity indicates that a generator may accumulate up to 2.2 pounds or 1 kilogram of acute hazardous waste that are physically solid or 1 quart of liquid acute hazardous waste at or near the initial generation point without additional requirements for management. The rule contrasts with the 55-gallon threshold that applies to non-acute dangerous waste.

Learn More About Acute Hazardous Waste From Hazmat School

Acute hazardous wastes are handled differently from other types of waste because they pose a significant threat to humans and the environment, even in small quantities. They require more stringent requirements, making it essential to be aware of the laws and regulations. Besides ensuring compliance, it helps when employers take steps to improve workplace safety.

Hazmat School provides training and certification for individuals and businesses handling hazardous waste. Our RCRA hazardous waste generator program is designed to be self-paced, convenient and practical, with experienced remote instructors available to assist you. Do you want to build a comprehensive safety culture and meet your compliance goals? Contact us today!

Kirstie Chisholm

Manages Hazmat School’s E-Learning courses and blog. Kirstie has extensive experience in the online training and education industry. Kirstie has worked with courses that offer a variety of safety and environmental certifications that satisfy OSHA, EPA and DOT requirements.