Wastes that are potentially hazardous because of toxicity require a hazardous – non-hazardous determination through laboratory analysis using the Toxicity Characteristic Leaching Procedure (TCLP) testing protocol. Submitting a representative waste sample to a laboratory for TCLP analysis is the only accurate and defensible way to determine if a waste is hazardous or non-hazardous due to the characteristic of toxicity.
A representative sample consists of a waste that is normally generated and disposed. It may be a composite sample made up of small amounts of waste generated over time or a grab sample collected from a container used to store the waste. The laboratory will determine how much of a waste sample must be collected to conduct the TCLP analyses. Samples should be taken with clean equipment and containers supplied by the laboratory selected to do the analyses. Although 40 TCLP contaminants are on EPA’s toxicity list, wastes need only be tested for the toxins likely to be present.
Waste is hazardous from toxicity if any TCLP parameter is detected at a concentration equal to or greater than its corresponding regulatory limit. Hazardous waste must be managed in accordance with hazardous waste management regulations and disposed through an EPA-permitted hazardous waste management company. Non-hazardous waste may be landfilled or managed through any reputable waste management company.