HAZARDOUS WASTE CHARACTERIZATION: MANAGING 'CRADLE TO GRAVE' LIABILITY

Under RCRA (Resource Conservation and Recovery Act), a generator's liability for hazardous waste is absolute. It lasts from the moment the waste is generated until the end of time—even after it has been shipped off-site. This "Cradle to Grave" liability means that accurate characterization is not just a lab task; it is a risk management necessity.

The Cost of Mischaracterization

We frequently encounter facilities that classify everything as "hazardous" just to be safe. While this ensures compliance, it is financial malpractice. Hazardous waste disposal costs 5x-10x more than non-hazardous disposal. Conversely, classifying hazardous waste as non-hazardous invites EPA enforcement actions and six-figure fines.

Our Process: Profile, Segregate, Dispose

Mercy Environmental implements a rigorous waste stream analysis for our clients:

• Source Reduction: We identify process changes that prevent the waste from becoming hazardous in the first place (e.g., substituting solvents).
• Precise Profiling: Using EPA SW-846 test methods, we determine if waste meets the criteria for Ignitability (D001), Corrosivity (D002), Reactivity (D003), or Toxicity (D004-D043).
• TSDF Auditing: We only approve Treatment, Storage, and Disposal Facilities (TSDFs) that meet our internal safety standards, protecting our clients from future Superfund liability.