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What is a Hazardous Waste Determination?
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A hazardous waste determination is a procedure used to determine whether a waste is
hazardous. All wastes generated from a business must be evaluated to determine if that
waste is a hazardous wastel
D
D What is a Hazardous Waste?

A hazardous waste is a solid, liquid or gaseous material that you no longer use, and either
recycle, discard, or store until you have enough to dispose of proper~y. Hazardous wastes
D have certain properties that may cause serious injury or death or may pollute the land, air,
groundwaters and surface waters of the state if not properly handled.

D A waste may be hazardous either because it is specifically listed in the regulations (40
CFR 261 Subpart D) or because it exhibits certain characteristics. These characteristics
are as follows:

Characteristic Waste Waste Streams that

Code may Exhibit one or
more Characteristics

iIgnitability: a liquid waste that has a flash point DO01 Spent solvents, spent still
lower than 140°F, ignitable solids, ignitable bottoms, mineral spirits, oil-
compressed gases and oxidizers based paints, waste gasoline,
old signal flares

Corrosivity: a waste that has a pH less than or equa~ D002 Acid from lead-acid batteries
to 2.0 or ~reater than or equal to 12.5 certain cleaners

Reactivity: a waste that is unstable, reacts violently, D003 Sodium azide in undeployed
explodes or emits toxic fumes when mixed with airbags
water or is capable of exploding at room temperature
and pressure

Toxicity: a waste that contains certain toxic organic D004- Sludges, waste gasoline,
chemicals or certain heavy metals such as cadmium, D043 contaminated oils, lead-acid
chromium, lead or mercury batteries, mercury switches,
lead wheel weights, certain
~esticides and herbicides

How Do I Conduct a Hazardous Waste Determination?

A hazardous waste determination may be conducted either by having the waste tested by
a state certified laboratory or by applying knowledge of the waste and its hazard
characteristics. If applying knowledge, you must be able to clearly demonstrate how the
knowledge was correctly applied in making the determination. For a current list of state
certified laboratories go to www.dph.state.ct.us/BRS/Environmental lab/
InstateLabList.html

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 Air bag cartridges contain an explosive chemical, sodium azide. If the air bag has not
been deployed, the materia~ is dangerous to handle. It can explode, cause burns if it
gets on unprotected skin, and severely irritate the lungs if inhaled.
How Do I Manage Air Bags?

Undeployed air bags should never go through a crusherl Many vehicles now contain
multiple air bags. Be sure to remove al~ undeployed airbags prior to crushing.
Air bag cartridges that have not been deployed are a hazardous waste unless they are
reclaimed. If you plan to dispose of air bag cartridges, they must be managed as a
hazardous waste.

If the air bags have been deployed, the material is no longer dangerous, and you will not
have to take special precautions. If a vehicle contains a deployed air bag, the air bag
does not need to be removed prior to crushing.
Store undeployed air bags indoors, protected from the weather, until they can be
resold.
If airbags are being sold for reuse, maintain the shipping papers on-site that indicate
the name of the reclaimer, the date of transfer, and the quantity of air bags/cartridges
shipped for at least three years.

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 Mercury is released into the environment when
mercury switches are not removed prior to
compacting or shredding vehicles. Mercury is
highly toxic to humans and the environment. It
accumulates in the tissues of fish and other
organisms in mercury-containing water and may
be carried up the food chain to humans.

Where Is Mercury Found on a Vehicle?

Vehicle trunk and hood light switches can

contain mercury. A mercury switch is probably
being used if the light goes on when the hood
is partway up, or you can see that the bulb housing is deliberately mounted at an angle to
the hood. Most cars containing mercury switches are American makes and models.

In addition to the mercury switches in convenience lighting, some relays may contain
mercury switches to activate airbags, anti-lock brakes (primarily found in four-wheel drive
vehicles), some seat be~t systems, and some automatically adjusting suspension systems.
Some agricultural equipment, military vehicles, mass transit vehicles, and fire hook and
ladder equipment also contain mercury switches.

How Are the Switches Removed and Managed?

Remove the mercury switches before the vehicle is crushed. This can be done at
the same time as removal of vehicle fluids, batteries, refrigerants and non-
deployed airbags.
Cut the power supply wire attached to the base of the light fixture
Remove any fasteners in order to separate the entire fixture from the vehicle.
Carefully remove the mercury switch from the fixture. If the switch cannot easily
be removed, put the entire fixture in the collection container. Removing the
switch from the fixture will save storage
space and may also save on disposa~ costsl
o;o If the switch or the assembly
looks damaged or corroded, place the
fixture in a separate plastic container, like
a yogurt tub, to prevent leakage.
o;o Place switches in a covered, heavy
p~astic labeled container with secondary
containment. Do not use tin or aluminum
containers because mercury may combine
with these metals and leak through the
seams1 Mercury is classified as a
hazardous waste with waste code DO09.

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