Learning Goals
Learn the four major categories of RCRA hazardous waste, the "lists."

RCRA is the US cradle-to-grave hazardous waste law. In a later module we will get into some of the administrative details of RCRA. Here we want to dispose of two main issues. What is waste? And what is a RCRA hazardous waste? RCRA has some exceptions - things you would expect are hazardous waste but are excluded from the RCRA cradle-to-grave system. Some of these exceptions were pure politics when the law was passed. But more often it was because the waste was regulated by a different law. For example radioactive waste was already highly regulated when RCRA was passed. Also, as you see in the cartoon, discharges to air and water were also regulated by different laws. RCRA chiefly regulates solid waste. What is solid waste? It is just what Junior Soprano trucked back to his rented lot. Liquids are "solid waste" if they are in barrels or tanks. So are gasses, if they are contained in cylinders or tanks.

What is a "solid waste": It is any discarded material, including garbage, refuse and sludge that is not otherwise excluded. Some exceptions are sewage sludge and industrial wastewater subject to permits under a regulatory scheme other than RCRA.

Once an industry has a solid waste it next must determine if it is a hazardous waste. The RCRA law has a definition which I'll paraphrase:

A lawyer would enjoy defending a wealthy client accused under this law, "substantial ...potential hazard to... environment" is vague enough to indict anybody but convict nobody. So the EPA, who is charged by RCRA to make regulations, had developed regulations to define "hazardous waste." You may have guessed, the method involves lists. It also uses a test of "characteristics." We will discuss both.


Module 3 Index

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