Greetings,
The statement at 9.4.1 discussing hazardous waste could lead some to believe
that they have a choice as to which of the methods you describe to use.  In
fact they need to assess the waste against both criterea.

See 40 CFR 262.11  EPA suggests the following:
First determine if the waste is excluded  (262.11 (a))

Then "He MUST then determine if the waste is listed....in Subpart D (the
listed wastes)" (262.11 (b))

Finally in order to comply with the Part 268 land ban "or if the waste is
not listed in Subpart D...the generator MUST then determine whether the
waste is identified in Subpart C (criterea wastes)" (262.11 (c))

The emphasis is mine. The listing in Subpart D is designed to make it
"easier" for the regulated entities by providing the applicable
characteristic code for the listed wastes.  A good example is the F003
solvent where they state that the applicable code is (I)* and the asterisk
says to list (I,T) if the material also contains toxic chemicals.

I would suggest the following change to 9.4.1:

9.4.1  RCRA - Hazardous Waste. In order for industry to establish if a solid
waste is hazardous waste under RCRA, the generator must:

My thoughts only
__________________________________________
Dan Kallin                        Environmental Engineer
   Bose Corporation       Framingham, MA 01701
                 [log in to unmask]
                 508-766-7136  (phone)
                 508-766-7086   (fax)
-------------------------------------------

+++++++++++++++++++++++++++++++

9.4.1  RCRA - Hazardous Waste. There are two ways for industry to establish
if a solid waste is hazardous waste under RCRA:

Determine if the material is listed as hazardous waste on the
commercial-chemical (P&U waste), specific-source (K wastes), or
nonspecific-source (F wastes) lists.

Determine if the waste exhibits one of the four characteristics of hazardous
waste - ignitability, corrosivity, reactivity, or toxicity.

If the waste meets any of the four characteristics, or is listed, it is
generally a hazardous waste regulated by RCRA.

>
> As per our conversation, attached IPC-SC-60A Section 9 in Word 97 format.
> Feel free
> to make whatever changes you like.  I would rather have a major change now
> than to
> publish an outdated document.
>
> I would like to have this done as soon as you could because this is the
> only bottle
> neck towards publication of the document.
>
> Thank you so much for your help.
>
> Have a good day.
>
> Jane
>
>
>
>

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