Hazard classification procedures

Hazardous waste identification To facilitate the proper identification and classification of hazardous waste, RCRA begins with hazardous waste identification procedures. 

Richard P. Gen on i is a principal engineer with Duratek Federal Services Northwest Operations in Richland, Washington. Genoni maintains the Explosive Classification Tracking System for the Department of Energy s National Transportation Program and reviews all new explosive applications before submittal to the Department of Transportation. He also maintains Department of Energy Interim Hazard Classifications in accordance with the Department of Defense Ammunition and Hazard Classification Procedures, TB 700-2. 

Hazards classification is the assignment of a material or an end item (in this case only in-process materials) to a particular hazard class which best describes the threat presented by the material. This requires the use of a hazards classification procedure which provides the guidelines and criteria on which the choice of the hazards class is based. The assigned hazards, class of the material is then used as the basis for selecting the proper quantity-distance relationship. Thus, if the hazards classification procedure erroneously assigns a material to the wrong class, either safety is compromised or excessive safety requirements are imposed. Both possibilities are expensive. 

The objective of this program is to establish hazard classification procedures, as a supplement to the existing regulatory manual, for in-process materials used during the various stages of propellant and explosive manufacture. 

To accomplish this objective, a review of the current hazard classification schemes was conducted. Major deficiencies were uncovered. They related to the classification procedures, to the implementation of the procedures, and to the final usage of the... 

Physical and chemical tests of the final product may need to address two concerns (1) whether the solidified waste exhibits any RCRA defined toxicity characteristics or could be delisted and (2) the potential long term fate of treated materials in the disposal environment. Three tests are available which address the first concern. These are the Extraction Procedure (EP Tox) (40 CFR 261, Appendix II, 1980) and the Toxicity Characteristic Leaching Procedure (TCLP) (40 CFR 261, Appendix II, 1986), and the Multiple Extraction Procedure Test (40 CFR 261, Appendix II, January 1989). It is important to note that these tests are not indicators of expected leachate quality but of potentials. A solidified product which cannot pass the appropriate test (EP Tox or TCLP) would be subject to classification as a hazardous waste. 

Various secondary sources of safety data are now listing this as an explosive. I can find no primaiy source for this classification, which seems very improbable. Simple minded use of many computational hazard prediction procedures would show thermodynamically that this compound, like most lower amines, could hypothetically convert to alkane, ammonia and nitrogen with sufficient energy (about 3 kJ/g) to count as an explosion hazard. This reaction is not known to happen. (Simple minded thermodynamicists would rate this book, or computer, and its reader as a severe hazard in an air environment.) Like other bases, iminobispropylamine certainly sensitises many nitro-explosives to detonation. It is used experimentally to study the effect, which may have found technical exploitation and, garbled, could have led to description of the amine as itself an explosive. 

The United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS) includes an internationally standardized guidance procedure on Transformation/Dissolution Protocol (T/DP) for metals and sparingly soluble metal compounds (United Nations, 2007), recently validated by the OECD (Organization for Economic Cooperation and Development). To establish the acute aquatic hazard classification level of a metal-bearing substance under the GHS, data from the T/DP are compared with an acute ecotoxicity reference value (ERV) derived under conditions similar to those of the T/DP. 

The results of a number of tests such as those described in Chapter 2 led to classifications for the peroxide group. These tests included the determination of the hazards of decomposition (deflagration and detonation), bum rate, fire hazard, and reactivity hazards. Five different classes were formulated, as listed in the NFPA 43B Hazard Class, from the test results. Emergency procedures have been established for these five classes. 

In terms of waste definition, there are three basic approaches (as it pertains to petroleum, petroleum products, and nonpetroleum chemicals) to defining petroleum or a petroleum product as hazardous (1) a qualitative description of the waste by origin, type, and constituents (2) classification by characteristics based on testing procedures and (3) classification as a result of the concentraUon of specific chemical substances. 

The criteria and procedural methods for characterising substances with regard to their hazardous characteristics and risk characterisation are harmonised in Europe. There also exists a common European system for the classification and labelhng of hazardous substances and for safety data sheets. Officially harmonised classifications also exist for around 3000 substances. The individual elements of the current system as well as its weaknesses are to be explained in the following section. 

ECETOC (2004) has proposed a concept of generic threshold values based on hazard categories primarily intended to be used in the risk assessment procedure of industrial chemicals within REACH. The hazard categories are based on EU classihcation limits and for each substance to be risk assessed, inclusion in hazard categories depends on the substance s specific classification (or no classification) according to the Commission Directive 67/548/EC (EC 1967). Three hazard categories have been suggested ... 

FDA. 1970. Food and Drug Administration. Part 191-Hazardous substances definitions and procedural and interpretive regulations. Carbon tetrachloride findings of fact and conclusions and final order regarding classification as banned hazardous substance. Federal Register. 35 13198-13205. 

The basic idea of the CLH process is the transfer of responsibility for classification and labeling from industrial companies to authorities on a European Community level. In case of active substances in biocidal or plant protection products, all intrinsic properties including physicochemical properties, human health hazards, and environmental hazards are subject to the harmonization. By contrast, in the case of chemicals which are used in other application fields only some specific hazard classes are considered in the CLH procedure. According to Article 36 of the CLP Regulation, these are respiratory sensitization, carcinogenicity, germ cell mutagenicity, and reproductive toxicity. Consequently, these provisions have... 

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