The Environmental Protection Agency (EPA) has the primary responsibility of determining if material used during the industrial, manufacturing, or service -related processes constitute a hazard to humans, animals, and/or plant life; or pollute the land, air, or water. Companies can determine if the waste generated by their operations is classified if it appears on any one (or more) of the four hazardous waste lists: F, P, K, or U, as outlined in the federal regulations.
The EPA listings contain over 400 hazardous wastes, including specific wastes derived from manufacturing processes and discarded commercial chemical products. This article covers the basics of K listed hazardous wastes.
The K hazardous waste listing is covered under CFR 40 CFR Part 261.32. This category is similar to the P listing because it denotes waste generated from manufacturing processes. However, the primary difference is that K listings come from specific manufactured and industrial generators, and the waste contains chemicals that have been used for their intended purpose. To determine if your waste stream qualifies as a K listed waste, you must answer two key questions:
- Is the facility that created the waste identified as one of the manufacturing or industrial entities contained in the K listing?
- Does the waste generate by the company match one of the specific K list waste descriptions?
As a waste generator, you must determine if your waste meet the EPA's regulation’s definition of a waste and the category that applies.
Industries that Generate K List Waste
Wastes that appear on one of the four lists have been classified as hazardous because they contain any number of toxic constituents, which have been shown to be harmful to health and/or the environment.
Many manufacturers and industrial companies generate hazardous wastes. Larger companies that fabricate various goods and products tend to be the largest generators of hazardous waste streams. Service-oriented businesses are to create smaller amounts of hazardous waste.
Regardless of the size of your business operations, one of the keys to staying in compliance with federal and state regulations is to know the amount and the volume of hazardous waste generated by your operations.
The EPA indentifies 13 industries that can generate K listed wastes. However, it is important to remember that not all wastes produced by these industries fit the designation of hazardous waste. Hazardous waste streams must meet the elements described in the K list descriptions to qualify under the EPA guidelines. Here are the13 industries that qualify for the generation of K list waste:
- Wood preservation
- Inorganic pigment manufacturing
- Organic chemicals manufacturing
- Inorganic chemicals manufacturing
- Pesticides manufacturing
- Explosives manufacturing
- Petroleum refining
- Iron and steel production
- Primary aluminum production
- Secondary lead processing
- Veterinary pharmaceuticals manufacturing
- Ink formulation
- Coking --processing of coal to produce coke, a material used in iron and steel production
According to the EPA, approximately 100 facilities across the nation generate hazardous waste covered by the K listing. In comparison, thousands of manufacturing and industrial operations generate spent solvent wastes as contained in the F listing. Among the 13 industries that create waste streams describe in the K listing, companies involved in petroleum refinery and wood preservation operations can also create F-listed wastes.
Comparing the K- and F- Listings
Typically, K listings describe more specific waste streams than F listings applicable to the same industry. The EPA provides the following example: K051 and K048 designate as hazardous two very specific types of petroleum refinery wastewater treatment residues: wastewater treatment sludges produced in API separators and wastewater treatment float created using dissolved air flotation (DAF) pollution control devices.
The F list contains F037 and F038 listings, which complement the two K listings, identifies all other types of wastewater treatment sludges and floats generated from petroleum refinery operations as hazardous. This example demonstrates the specificity of the K listing as oppose to F listing, as well as the similarity of the two categories.
Depending on the products you manufacture or your industry, it is possible that the waste produced from your operations will apply to two designations or categories. Generally, the primary ingredients contained in the waste will determine the primary category, and the other classification will be noted on the manifest. This type of waste generation may be confusing, it is best to contact your state EPA or a hazardous waste disposal expert for technical assistance.