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🧾 Lead Waste Classification Under RCRA

Lead waste disposal rules: D008/TCLP limits, RCRA & universal waste options + PureWay solutions for safe, compliant lead material handling.

Updated over 3 months ago

🧪 1. Toxicity Characteristic (TC) Hazardous Waste

Lead is listed on the Toxicity Characteristic Leaching Procedure (TCLP) list, which is used to determine whether a waste exhibits hazardous characteristics under 40 CFR § 261.24.

  • EPA Waste Code: D008

  • TCLP Regulatory Limit: 5.0 mg/L (milligrams per liter)

  • If a waste leaches lead at or above this level in a TCLP test, it is a characteristic hazardous waste.


🧾 2. Listed Hazardous Waste

Lead may also be part of a listed hazardous waste if it is generated from specific industrial processes (e.g., battery manufacturing, metal finishing). These carry F-codes, K-codes, or P/U-codes, depending on the source.


🧨 Common Examples of Lead Waste

Type

Likely Classification

Lead-acid batteries

Universal Waste or Hazardous Waste (D008)

Lead aprons (medical/dental)

Often considered hazardous if TCLP fails

Spent ammunition/bullets

Can be hazardous depending on leachability

Lead-based paints (pre-1978)

Often D008 hazardous waste if not removed properly

X-ray shielding materials

May require testing, often fall under D008


📦 Management & Disposal Requirements

✔️ If Classified as Hazardous Waste (D008)

  • Must be managed under RCRA Subtitle C requirements:

    • Use an EPA ID number

    • Store in properly labeled containers (e.g., “Hazardous Waste – D008, Lead”)

    • Comply with accumulation time limits and storage standards

    • Manifest for shipment to a TSDF (Treatment, Storage, and Disposal Facility)

✔️ If Eligible as Universal Waste (e.g., batteries):

  • Can be managed under less stringent standards per 40 CFR Part 273

  • Must still prevent releases and track shipments


🚫 Illegal Disposal Warning

Improper disposal of lead-containing waste (e.g., tossing in regular trash or autoclaving lead aprons) can trigger:

  • Civil and criminal penalties

  • EPA enforcement actions

  • Worker safety violations under OSHA


✅ How PureWay Can Help

PureWay offers compliant disposal solutions for:

  • Lead aprons and shielding material

  • Spent lead-acid batteries (as universal waste)

  • Waste characterization and profiling support

  • Waste pickup services and mail-back kits (where applicable)

  • Documentation and training to meet RCRA and OSHA requirements

👉 Visit PureWay Hazardous Waste Services for more info.

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