🧪 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.