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10/6/2006

D003 Characteristic of Reactive Hazardous Waste [40 CFR 261.23]


Unlike the D001 and D002 waste codes, where there are test methods that may be used to determine if a solid waste displays that particular characteristic, the D003 definition at 40 CFR 261.23 does not have a designated test method to help in waste classification. Each property of the D003 code is a narrative description. If a solid waste displays any one of these eight descriptions, then it displays the reactivity characteristic and is a D003 hazardous waste.

Unfortunately, because neither 40 CFR 261.23 nor EPA’s Handbook, “Test Methods for Evaluating Solid Waste” (SW-846) prescribe methods for characterizing D003, this can make it difficult for a waste generator. If an EPA or state inspector believes that a waste stream exhibits the reactivity characteristic, it is up to the generator to prove the inspector wrong if the generator believes the waste is not reactive. Without an approved test method, this can be difficult.

If a laboratory tells you it can do a D003 reactive cyanides and sulfides test, it is probably testing for total or chlorine-amenable cyanides and sulfides. This does not necessarily show whether a waste is reactive or not.

To learn more about how to properly classify and manage hazardous waste properly, attend Environmental Resource Center’s Advanced Hazardous Waste Management Course or Hazardous Waste Management: The Complete Course.