7/26/2012
How to Determine if Your Spent Solvent is F001 or F002 Hazardous Waste [40 CFR 261.31]
Environmental
If you generate spent solvents, you must determine if your waste is covered by any of the hazardous waste descriptions on the F-list. The chemicals identified in F001 and F002 are somewhat similar, but as described below, their waste descriptions are significantly different.
| F001 | F002 |
| Tetrachloroethylene | Tetrachloroethylene |
| Trichloroethylene | Trichloroethylene |
| Methylene chloride | Methylene chloride |
| 1,1,1-trichloroethane | 1,1,1-trichloroethane |
| Carbon tetrachloride | Chlorobenzene |
| Chlorinated fluorocarbons | 1,1,2-trichloro-1,2,2-trifluoroethane |
| | Ortho-dichlorobenzene |
| | Trichlorofluoromethane |
| | 1,1,2-trichloroethane |
The difference in these two codes is in the first sentence of the F001 listing, which states: "The following spent halogenated solvents used in degreasing...." The F002 listing also applies to spent halogenated solvents but does not apply to degreasing.
The term degreasing refers to large scale industrial degreasing equipment and operations. The document "Listing of Hazardous Waste (40 CFR 261.31 and 261.32); Identification and Listing of Hazardous Waste Under RCRA, Subtitle C, Section 3001" (known as the Background Listings Document) clarifies the intent of the F001 listing compared to other spent solvents. The F001 listing is appropriate when these solvents are used in large-scale industrial degreasing operations (e.g., cold cleaning, vapor degreasing, and fabric scouring). Alternatively, the same solvents used in equipment cleaning or in smaller scale degreasing operations involving repair work (that do not employ industrial degreasing processes as described above), such as industrial, maintenance and repair, commercial service and repair, and consumer-performed maintenance and repair, receive the F002 listing.
To ensure that your hazardous wastes are managed properly, attend Environmental Resource Center's Hazardous Waste Management - The Complete Course, or a state-specific hazardous waste management course in California or Texas.