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RCRA Characteristic Screener

  1. Is the material a solid waste — has it been discarded (abandoned, disposed of, burned, or recycled in a manner constituting disposal), rather than being a product still in use?

    RCRA hazardous-waste rules only reach materials that are first "solid wastes" under 40 CFR 261.2. "Solid waste" includes liquids, semi-solids, and contained gases — the word "solid" is not about physical state.

  2. Is the waste excluded from regulation as a hazardous waste under 40 CFR 261.4(b)?

    Examples of 261.4(b) exclusions: household waste, certain fossil-fuel combustion wastes, and certain oil- and gas-exploration/production wastes, among others.

  3. Have you checked the F, K, P, and U hazardous-waste lists (40 CFR 261.31–261.33), and does the waste appear on any of them (or derive from a listed waste)?

    The generator is legally responsible for making this determination (40 CFR 262.11). A listed waste is hazardous regardless of what the characteristic questions below would say.

  4. Ignitability (D001): does the waste have any of these properties?

    1. A liquid with a flash point below 60 °C / 140 °F — excluding aqueous solutions with less than 24% alcohol by volume and at least 50% water by weight.
    2. A non-liquid capable, at standard temperature and pressure, of causing fire through friction, absorption of moisture, or spontaneous chemical changes, and when ignited burns so vigorously and persistently that it creates a hazard.
    3. An ignitable compressed gas.
    4. An oxidizer (e.g. a chlorate, permanganate, inorganic peroxide, or nitrate that readily yields oxygen).

  5. Corrosivity (D002): does the waste have either of these properties?

    1. It is aqueous with pH ≤ 2 or ≥ 12.5.
    2. It is a liquid that corrodes SAE 1020 steel at more than 6.35 mm (0.250 inch) per year at 55 °C (130 °F).

    Under the federal rule the pH prong applies only to aqueous wastes and the steel prong only to liquids — a dry solid cannot be federally D002 (some states regulate corrosive solids; check your state).

  6. Reactivity (D003): does the waste have any of these properties?

    Normally unstable and readily undergoes violent change without detonating; reacts violently with water; forms potentially explosive mixtures with water; when mixed with water generates toxic gases, vapours, or fumes in a quantity dangerous to human health or the environment; is a cyanide- or sulfide-bearing waste that can generate such toxic gases when exposed to pH between 2 and 12.5; is capable of detonation or explosive reaction under a strong initiating source or when heated under confinement; is readily capable of detonation or explosive decomposition at standard temperature and pressure; or is a forbidden explosive or a Division 1.1, 1.2, or 1.3 explosive under DOT rules.

    Reactivity is a narrative standard — there is no numerical test threshold in the regulation. It is typically determined from process knowledge.

  7. Toxicity (D004–D043): using the Toxicity Characteristic Leaching Procedure (SW-846 Method 1311), does the extract from a representative sample contain any contaminant in the table below at or above its regulatory level?

    If the waste is less than 0.5% filterable solids, the filtered waste itself is the extract.

    TCLP Table 1 — maximum concentration of contaminants for the toxicity characteristic, 40 CFR 261.24
    EPA HW No.ContaminantCAS No.Reg. level (mg/L)
    D004Arsenic7440-38-25.0
    D005Barium7440-39-3100.0
    D018Benzene71-43-20.5
    D006Cadmium7440-43-91.0
    D019Carbon tetrachloride56-23-50.5
    D020Chlordane57-74-90.03
    D021Chlorobenzene108-90-7100.0
    D022Chloroform67-66-36.0
    D007Chromium7440-47-35.0
    D023o-Cresol495-48-7200.0
    D024m-Cresol4108-39-4200.0
    D025p-Cresol4106-44-5200.0
    D026Cresol (total)4—200.0
    D0162,4-D94-75-710.0
    D0271,4-Dichlorobenzene106-46-77.5
    D0281,2-Dichloroethane107-06-20.5
    D0291,1-Dichloroethylene75-35-40.7
    D0302,4-Dinitrotoluene3121-14-20.13
    D012Endrin72-20-80.02
    D031Heptachlor (and its epoxide)76-44-80.008
    D032Hexachlorobenzene3118-74-10.13
    D033Hexachlorobutadiene87-68-30.5
    D034Hexachloroethane67-72-13.0
    D008Lead7439-92-15.0
    D013Lindane58-89-90.4
    D009Mercury7439-97-60.2
    D014Methoxychlor72-43-510.0
    D035Methyl ethyl ketone78-93-3200.0
    D036Nitrobenzene98-95-32.0
    D037Pentachlorophenol87-86-5100.0
    D038Pyridine3110-86-15.0
    D010Selenium7782-49-21.0
    D011Silver7440-22-45.0
    D039Tetrachloroethylene127-18-40.7
    D015Toxaphene8001-35-20.5
    D040Trichloroethylene79-01-60.5
    D0412,4,5-Trichlorophenol95-95-4400.0
    D0422,4,6-Trichlorophenol88-06-22.0
    D0172,4,5-TP (Silvex)93-72-11.0
    D043Vinyl chloride75-01-40.2
    1. 3 Quantitation limit is greater than the calculated regulatory level; the quantitation limit therefore becomes the regulatory level.
    2. 4 If o-, m-, and p-cresol concentrations cannot be differentiated, the total cresol (D026) concentration is used; the regulatory level of total cresol is 200 mg/L.
  8. Out of scope

    Not a solid waste — characteristics don't apply

    Based on your answer, the material is not a solid waste, so the federal hazardous-waste characteristics do not apply to it. If its status changes — it is spilled, abandoned, taken out of service, or sent for disposal — re-run this determination at that point.

    Basis: 40 CFR 261.20(a)

  9. Needs review

    Recycling status is fact-specific — check §261.2

    Whether a recycled or reclaimed material counts as a solid waste depends on the specific recycling activity under 40 CFR 261.2 and the exclusions in 261.4(a). That analysis is fact-specific and this tool won't guess at it. Review 261.2's recycling table and 261.4(a), or speak with an environmental professional, then return with a yes/no.

    Basis: 40 CFR 261.2, 261.4(a)

  10. Excluded

    Excluded under 261.4(b)

    A waste covered by a 261.4(b) exclusion is not a RCRA hazardous waste even if it would otherwise exhibit a characteristic. Document which exclusion you are relying on and why it applies — that record is what an inspector will ask for. State programs can be narrower than the federal exclusions; check your state.

    Basis: 40 CFR 261.20(a), 261.4(b)

  11. Needs review

    Check the full 261.4(b) exclusion list

    Whether an exclusion applies is specific to your waste. Review the full list at 40 CFR 261.4(b), confirm which entry fits (and that your state recognises it), then return with a yes/no rather than relying on a guess here.

    Basis: 40 CFR 261.4(b)

  12. Listed-waste path

    Listed waste — determine from the lists themselves

    A waste on the F, K, P, or U lists is a hazardous waste through the listing itself — the characteristic screen doesn't change that, and mixture/derived-from rules can extend the listing to residues and mixtures. This tool covers the characteristic path only; work the listing determination from 40 CFR part 261 subpart D and EPA's hazardous-waste listings.

    Basis: 40 CFR 261.30–261.35; 262.11

  13. Check the lists

    Check the F/K/P/U lists first

    Checking the F, K, P, and U lists is a required part of the determination under 40 CFR 262.11 — do that first, then return. Work from 40 CFR part 261 subpart D and EPA's hazardous-waste listings. A listed waste is hazardous regardless of the characteristic answers.

    Basis: 40 CFR 261.30–261.35; 262.11

  14. Hazardous waste

    Exhibits a characteristic — it is a RCRA hazardous waste

    Based on your answers, the waste exhibits at least one hazardous-waste characteristic and is a RCRA hazardous waste. A characteristic waste carries every applicable EPA Hazardous Waste Number (40 CFR 261.20(b)).

    Next steps: determine your generator category under 40 CFR 262.13 (very small / small / large quantity generator — it drives accumulation limits, manifesting, and reporting), and check your state program, which may add state-only codes or stricter rules.

    Applicable EPA Hazardous Waste Numbers from your answers:

    the characteristic(s) you confirmed above.

    Basis: 40 CFR 261.20(b); 261.21–261.24

  15. Not a characteristic

    Does not exhibit a federal characteristic

    Based on your answers, the waste does not exhibit any of the four federal characteristics, and you indicated it is not a listed waste. Keep the record of how you made this determination — 40 CFR 262.11 places the determination duty on the generator, and the documentation is the deliverable. Some states regulate additional wastes (state-only listings and characteristics).

    Basis: 40 CFR 261.20–261.24; 262.11

  16. Testing needed

    Unresolved — this tool won't determine it

    One or more characteristics could not be resolved, so this tool will not give you a determination. Testing (or a defensible knowledge-based determination) closes the gap; then re-run this screen. The applicable SW-846 methods are named below.

    Characteristics still unresolved:

    the characteristic(s) you marked as not tested above.

    Basis: 40 CFR 261.21–261.24; methods per 40 CFR 260.11

Reference only. Not legal or regulatory advice. Verify against the primary source before you act.

How it works

Under RCRA, a waste is hazardous if it is either listed (named on the F, K, P, or U lists in 40 CFR 261.31–261.33) or exhibits one of four characteristics — ignitability (D001), corrosivity (D002), reactivity (D003), or toxicity (D004–D043). This tool walks the characteristic path and includes the full TCLP Table 1 regulatory levels; listed-waste answers point you to the lists rather than guessing.

The duty to make this determination is the generator's, under 40 CFR 262.11 — and the documentation of how you decided is itself the deliverable an inspector will ask for. That is also why this tool refuses to answer on unknowns: if a characteristic hasn't been tested or resolved by defensible process knowledge, it names the SW-846 method to use instead of manufacturing a yes/no.

Federal scope only. State programs can be broader — additional listings, characteristics (e.g. corrosive solids), and stricter thresholds — so confirm against your state program. Sources (eCFR, title 40, current as of 2026-07-01): part 261 subpart C, part 261 (261.20–261.24).

Worked example

A spent xylene-based paint solvent sent for disposal, flash point about 27 °C:

solid waste (discarded) → no 261.4(b) exclusion → not listed → ignitable (liquid, flash point below 60 °C) → the screen lands on hazardous waste and lists D001 (ignitability). If TCLP later shows a metal at or above its Table 1 level, that D-number is added too.

Sources

  • Identification and listing of hazardous waste, characteristics (§§ 261.20 to 261.24)

    U.S. Environmental Protection Agency, eCFR, title 40, current as of 2026-07-01

    40 CFR part 261 subpart C

    Federal scope only. State programs can be broader, with additional listings, additional characteristics and stricter thresholds.

    open the source

  • Identification and listing of hazardous waste

    U.S. Environmental Protection Agency, eCFR, title 40, current as of 2026-07-01

    40 CFR part 261

    open the source

Related tools

Data vintage

  • Data: RCRA hazardous waste identification, U.S. Environmental Protection Agency eCFR Title 40, current as of 2026-07-01.Federal scope only. State programs can be broader, with additional listings, additional characteristics and stricter thresholds.

last updated 2026-07-03