What are Composites?

The term "composites" can be used in several different ways, and the definition can range from
general to very specific. Combining many individual photographs into one picture is known as a
composite photograph. It is a combination of different components. Composite materials are
also a combination of different components. A broad definition of a composite is: "Two or more
dissimilar materials which when combined are stronger than the individual materials."
Composites can be both natural and synthetic (or man-made).

Wood is a good example of a natural composite. Wood is a combination of cellulose fiber and
lignin. The cellulose fiber provides strength and the lignin is the "glue" that bonds and stabilizes
the fiber.

Bamboo is a very efficient wood composite structure. The components are cellulose and lignin,
as in all other wood, however bamboo is hollow. This results in a very light yet stiff structure.
Composite fishing poles and golf club shafts copy this natural design.

Plywood is a man-made composite combining natural and synthetic materials. Thin layers of
wood veneer are bonded together with adhesive to form flat sheets of laminated wood that are
stronger than natural wood.

There are other man-made combinations of natural materials that form useful composites. The
ancient Egyptians manufactured composites! Adobe bricks are a good example. The
combination of mud and straw forms a composite that is stronger than either the mud or the
straw by itself.

Concrete and steel combine to create structures that are rigid and strong. This is a classic
composite material where there is a synergy between materials. In this case, synergy means
that the composite (or combination) of materials is stronger and performs better than the
individual materials. Concrete is rigid and has good compression strength, while steel has high
tensile strength. The result is a structure that is strong in both tension and compression.

Another composite product with which we are all familiar is the rubber tire. A typical car tire
is a combination of a rubber compound and reinforcement such as steel, nylon, aramid, or
other fibers. The rubber acts as a matrix, holding the reinforcement in place. The matrix is the
glue that holds the fiber in place.

While the broad definition of composites is accurate, it is too general. A specific definition of
composites for our purposes is: "A combination of fiber reinforcement and a polymer matrix."
For example, polyester resin is the matrix and glass fiber is the reinforcement. The glass fiber
provides strength and stiffness, and the resin provides shape and protects the fibers.

The general definition of a composite is a combination of different components or elements.

For your work on the Composite Materials merit badge, however, think of a composite as a
material made from two or more dissimilar (not alike) materials that, when combined, are
stronger than those individual materials by themselves. For this merit badge, composites is
defined as “a combination of plastic resin and a fiber reinforcement.” Another term for
composites is used in the past is reinforced plastics.

Today, the composites industry uses a more specific term: fiber reinforced polymer (FRP)
composites. A polymer is a chemical compound made of many identical components linked
together like a chain. “Polymer” and “resin” are interchangeable terms. The fiber
reinforcement can be glass, carbon, or aramid (KevlarTM). These fibers are very strong.
The function of the fibers is to provide strength and stiffness to the composite product where
the resin acts to bond and protect the fibers from chemicals and the environment, as well as
transfer load between the fibers. Composites are different than other materials. For example,
metals are isotropic, meaning they have equal strength in all directions. Composites are
anisotropic, having different properties in different directions. This gives composites an
advantage by allowing designers to make efficient use of materials for the design loads.e

Manufacturers, designers, and engineers recognize the ability of composite materials to

produce high-quality, durable, cost-effective products. Composite materials are found in many
of the products used in our day-to-day lives – from the cars we drive, to the boats, RVs, skis
and golf clubs we use on the weekends. Additionally, composites are used in many critical
industrial, aerospace, and military applications.

In a marketplace where demands for product performance are ever increasing, composite
materials have proven to be effective in reducing costs and improving performance.
Composites solve problems, raise performance levels, and enable the development of many
new products.

In the United States, composites manufacturing is a 25 billion dollar a year industry, and it is
one of the few industries in which the U.S. is more advanced than most competitors abroad.
There are five to seven thousand composites related manufacturing plants and materials
distributors across the U.S. These facilities employ more than 236,000 people. An additional
250,000 people are employed in businesses that support the composites industry, including
materials suppliers, equipment vendors, and other support personnel.

About 90% of all composites produced are comprised of glass fiber and either polyester or vinyl
ester resin. 65% of composites are manufactured using the open molding method and the
remaining 35% are produced using closed molding or continuous molding methods.

Composites are broadly known as reinforced plastics. Specifically, composites are a reinforcing
fiber in a polymer matrix. Most commonly, the reinforcing fiber is fiberglass, although high
strength fibers such as aramid and carbon are used in advanced applications.

The polymer matrix is a thermoset resin with polyester, vinyl ester, and epoxy resins most
often being the matrix of choice. Specialized resins, such as phenolic polyurethane, and
silicone are used for specific applications.

Common household plastics such as polyethylene, acrylic, nylon, and polystyrene are known as
thermoplastics. These materials may be heated and formed and can be re-heated and returned
to the liquid state.

Composites typically use thermoset resins, which begin as liquid polymers and are converted to
solids during the molding process. This process, known as cross linking, is irreversible. Because
of this, these polymers are known as thermosets and cannot be melted and reshaped.

The benefits of composite materials have fueled growth of new applications in markets such as
transportation, construction, corrosion-resistance, marine, infrastructure, consumer products,
electrical, aircraft and aerospace and appliances and business equipment.

Why Composites Are Different

Composites have different properties than other materials. Metals for example have equal
strength in all directions. Composites can be custom tailored to have strength in a specific
direction. If a composite has to resist bending in one direction, most of the fiber can be
oriented at 900 to the bending force. This creates a very stiff structure in one direction. What
actually happens is that more of the material can be used where it counts. With metals, if
greater strength is required in one direction, the material must be made thicker overall, which
adds weight.

Composites differ from metals due to the wide range of material combinations that can be
used. Because of this, it is difficult to use a "handbook" approach to composites design. For
example, if one were looking for a steel I-beam to span 20 feet and carry a 2000-pound load,
you could simply open a structural steel handbook and choose the proper beam thickness and
flange width from a chart.

Composites are more complicated. The performance characteristics of composites can be

varied to a tremendous degree and there is no such thing as a "generic" or typical composite.
The very thing that makes composites a highly adaptable engineering material also makes them
more difficult to describe.

There are many combinations of resins and reinforcements used in composites. Each specific
material contributes to specific unique properties in the finished FRP product.

There are a number of different resins used in composites. These include: polyester, vinyl
ester, modified acrylic, epoxy, phenolic, and urethane resin systems. The list goes on;
however, the important point to note is that each of these resins has specific performance
characteristics. For example, if a product needs to be corrosion resistant, isophthalic or vinyl
ester resin might be used. If high strength is critical, an epoxy might be the resin of choice. If
product cost is an issue, polyester resin is most commonly used. In the realm of polyester resins
alone, different formulations will be used if cosmetics are important, if enhanced corrosion
resistance is required, if elevated temperatures will be encountered, or if cost is an overriding
factor. The resin system is selected based on the functional and cost requirements of the
product.

In addition to different resins, various types of reinforcement fibers are used in composites.
Glass fiber is used in over 90% of all composites. However, if required, advanced fibers such as
Kevlar or carbon fiber offer high level performance at a significant price. In the realm of glass
fiber, there are many "styles" of reinforcement. Depending on the molding process and the
strength requirements of the product there are many options.

Glass fiber is available in random fiber orientation in the form of chopped strand mat. There
are also lightweight textile fabrics, heavy woven materials, knitted fabrics, and unidirectional
fabrics that all serve specific purposes in composite design.

To maximize the cost/benefit of composite products, the component materials must be custom
tailored to the application. The ability to adapt composites over a wide range of requirements
makes them different from other materials.

Benefits of Composites

Light Weight - Composites are light in weight, compared to most woods and metals. Their
lightness is important in automobiles and aircraft, for example, where less weight means
better fuel efficiency (more miles to the gallon). People who design airplanes are greatly
concerned with weight, since reducing a craft’s weight reduces the amount of fuel it needs and
increases the speeds it can reach. Some modern airplanes are built with more composites than
metal including the new Boeing 787, Dreamliner.
High Strength - Composites can be designed to be far stronger than aluminum or steel. Metals
are equally strong in all directions. But composites can be engineered and designed to be
strong in a specific direction.

Strength Related to Weight - Strength-to-weight ratio is a material’s strength in relation to

how much it weighs. Some materials are very strong and heavy, such as steel. Other materials
can be strong and light, such as bamboo poles. Composite materials can be designed to be both
strong and light. This property is why composites are used to build airplanes—which need a
very high strength material at the lowest possible weight. A composite can be made to resist
bending in one direction, for example. When something is built with metal, and greater
strength is needed in one direction, the material usually must be made thicker, which adds
weight. Composites can be strong without being heavy. Composites have the highest strength-
to-weight ratios in structures today.

Corrosion Resistance - Composites resist damage from the weather and from harsh chemicals
that can eat away at other materials. Composites are good choices where chemicals are
handled or stored. Outdoors, they stand up to severe weather and wide changes in
temperature.

High-Impact Strength - Composites can be made to absorb impacts—the sudden force of a

bullet, for instance, or the blast from an explosion. Because of this property, composites are
used in bulletproof vests and panels, and to shield airplanes, buildings, and military vehicles
from explosions.

Design Flexibility - Composites can be molded into complicated shapes more easily than most
other materials. This gives designers the freedom to create almost any shape or form. Most
recreational boats today, for example, are built from fiberglass composites because these
materials can easily be molded into complex shapes, which improve boat design while lowering
costs. The surface of composites can also be molded to mimic any surface finish or texture,
from smooth to pebbly.

Part Consolidation - A single piece made of composite materials can replace an entire
assembly of metal parts. Reducing the number of parts in a machine or a structure saves time
and cuts down on the maintenance needed over the life of the item.

Dimensional Stability - Composites retain their shape and size when they are hot or cool, wet
or dry. Wood, on the other hand, swells and shrinks as the humidity changes. Composites can
be a better choice in situations demanding tight fits that do not vary. They are used in aircraft
wings, for example, so that the wing shape and size do not change as the plane gains or loses
altitude.

Nonconductive - Composites are nonconductive, meaning they do not conduct electricity. This
property makes them suitable for such items as electrical utility poles and the circuit boards in
electronics. If electrical conductivity is needed, it is possible to make some composites
conductive.

Nonmagnetic - Composites contain no metals; therefore, they are not magnetic. They can be
used around sensitive electronic equipment. The lack of magnetic interference allows large
magnets used in MRI (magnetic resonance imaging) equipment to perform better. Composites
are used in both the equipment housing and table. In addition, the construction of the room
uses composites rebar to reinforced the concrete walls and floors in the hospital.

Radar Transparent - Radar signals pass right through composites, a property that makes
composites ideal materials for use anywhere radar equipment is operating, whether on the
ground or in the air. Composites play a key role in stealth aircraft, such as the U.S. Air Force’s
B-2 stealth bomber, which is nearly invisible to radar.

Low Thermal Conductivity - Composites are good insulators — they do not easily conduct heat
or cold. They are used in buildings for doors, panels, and windows where extra protection is
needed from severe weather.

Durable - Structures made of composites have a long life and need little maintenance. We do
not know how long composites last, because we have not come to the end of the life of many
original composites. Many composites have been in service for half a century.

The Advantages of Composites

Composites offer a number of advantages over traditional engineering materials. These

beneficial characteristics have enabled the rapid acceptance of composites in many products.

High Specific Strength

Specific strength is a term that relates strength to weight. Composites have a higher specific
strength than many other materials. To understand this, consider the following example:

Compare a ¼ inch diameter steel rod to a ¼ inch diameter fiberglass composite rod.

• The steel rod will have higher tensile and compressive strength, but will weigh more.
• If the fiberglass rod were increased in diameter to the same weight as the steel rod, it
would be stronger.

Ability to Form Shapes

Composites can be formed into complex and accurate shapes easier than other materials. This
gives designers the freedom to create any shape or configuration. Boats are a good example of
the success of composites. Boats can be made out of a variety of materials – wood, aluminum,
steel, and even cement! Why are most pleasure boats today built from fiberglass composites?
The reason is that composites can be easily molded into complex shapes which improve boat
design.

Inherent Durability
How long do composites last? The answer is, we do not know…because we have not come to the
end of the life of many original composites. There are numerous examples of composites that
have been is service for forty to fifty years.

In 1947 the U.S. Coast Guard built a series of forty-foot patrol boats, using polyester resin and
glass fiber. These boats were used until the early 1970s when they were taken out of service
because the design was outdated. Extensive testing was done on the laminates after
decommissioning, and it was found that only 2-3% of the original strength was lost after
twenty-five years of hard service.

There are numerous examples of boats, buildings, and other composites structures built in the
1950s, which are still in service. The bodies of the original 1953 Corvette are fiberglass, and
with the exception of cosmetic repairs, are still structurally sound.

There are case histories of fiberglass ductwork being in service in chemical manufacturing
plants for over twenty-five years - operating in harsh chemical environments twenty-four hours
a day, seven days a week. How long do composites last? In many cases, over fifty years and still
counting!

Low Relative Investment

One reason the composites industry has been successful is because of the low relative
investment in setting-up a composites manufacturing facility. This has resulted in many
creative and innovative companies in the field.

Today, many of the largest composites molding companies have their roots in small
entrepreneurial companies that entered the business because of the low initial investment.
There are processes, such as thermoplastic injection molding, which require large multi-million
dollar investments in equipment. Open molding of composites requires a much more moderate
investment in equipment and molds. Although today, complying with regulations has added to
the cost of being in the composites business, the overall cost to enter the industry is less then
many other manufacturing ventures.

History of the Composites Industry

The use of natural composite materials has been a part of man's technology since the first
ancient builder used straw to reinforce mud bricks.

The 12th century Mongols made the advanced weapons of their day with archery bows that
were smaller and more powerful than their rivals. These bows were composites structures
made by combining cattle tendons, horn, bamboo, and silk which bonded with natural pine
resin. The tendons were placed on the tension side of the bow, the bamboo was used as a core,
and sheets of horn were laminated to the compression side of the bow. The entire structure
was tightly wrapped with silk using the rosin adhesive. These 12th century weapons designers
certainly understood the principles of composite design. In recent times some of these 700-
year old museum pieces were strung and tested. They were about 80% as strong as modern
composite bows.1

In the late 1800s canoe builders were experimenting with gluing together layers of kraft paper
with shellac to form paper laminates. While the concept was successful, the materials did not
perform well. Because the available materials were not up to the job, the idea faded.

In the years between 1870 and 1890, a revolution was occurring in chemistry. The first
synthetic (man-made) resins were developed which could be converted from a liquid to a solid
by polymerization. These polymer resins are transformed from the liquid state to the solid
state by crosslinking the molecules. Early synthetic resins included celluloid, melamine, and
Bakelite.

In the early 1930s two chemical companies that were working on the development of polymer
resins were American Cyanamid and DuPont. In the course of their experimentation, both
companies independently formulated polyester resin for the first time. In the same time
period, Owens-Illinois Glass Company began weaving glass fiber into a textile fabric on a
commercial basis.

During the time between 1934 and 1936, experimenter Ray Green, in Ohio, combined these two
new products and began molding small boats. This marks the beginning of modern composites.
During World War II the development of radar required non-metallic housings, and the U.S.
military advanced the fledgling composites technology with many research projects.
Immediately following World War II composite materials emerged as a major engineering
material.

The composites industry began in earnest in the late 1940s and developed rapidly through the
1950s. Most of the composites processing methods used today were developed by the year
1955. Open molding, hand lay-up, chopping, compression molding, filament winding, resin
transfer molding, vacuum bagging, and vacuum infusion were all developed and used in
production between 1946 and 1955. The products manufactured from composites during this
period included: boats, car bodies (Corvette), truck parts, aircraft components, underground
storage tanks, buildings, and many other familiar products.

The Composites Industry

The composites industry can be generally characterized by the markets that use composites
products. Composites are used to manufacture thousands of products that fall into three broad
categories: consumer composites, industrial composites, and advanced composites.

Consumer Composites
The composites industry has been in place for over fifty years, and consumer products such as
boats, automobiles and recreational products have been manufactured since the early 1950s.
Typically, although not always, consumer composites involve products that require a cosmetic
finish, such as boats, recreational vehicles, bath wear, and sporting goods. In many cases, the
cosmetic finish is an in-mold coating known as gel coat. Consumer products make up a large
portion of the overall composites market.

Industrial Composites
A wide variety of composites products are used in industrial applications, where corrosion
resistance and performance in adverse environments is critical. Generally, premium resins such
as isophthalic and vinyl ester formulations are required to meet corrosion resistance
specifications, and fiberglass is almost always used as the reinforcing fiber.

In many cases, cosmetic finishes are secondary to the performance of the product. Industrial
composite products include underground storage tanks, scrubbers, piping, fume hoods, water
treatment components, pressure vessels, and a host of other products.

Advanced Composites
This sector of the composites industry is characterized by the use of expensive, high-
performance resin systems and high-strength, high-stiffness fiber reinforcement. The aerospace
industry, including military and commercial aircraft of all types, is the major customer for
advanced composites.

These materials have also been adopted for use in sporting goods, where high-performance
equipment such as golf clubs, tennis rackets, fishing poles, and archery equipment, benefits
from the light weight – high strength offered by advanced materials. There are a number of
exotic resins and fibers used in advanced composites, however, epoxy resin and reinforcement
fiber of aramid, carbon, or graphite dominates this segment of the market.

Solid and Hazardous Waste

Scrap resin is considered a hazardous waste because it is flammable. Most other composite
industry waste streams, however, are not considered hazardous, including overspray, edge
trims, and scrap molding compound.

Should these other materials be managed as hazardous wastes? We believe not. ACMA is not
aware of any problems associated with the handling, storage, transportation, or disposal of
these materials. Further, styrene, the only “mobile” constituent of these materials that is
present in any appreciable concentration, rapidly degrades in the environment and has not
been found in groundwater around waste disposal operations. Finally, in its recent assessment
of the risk associated with releases of styrene, the Harvard Center for Risk Assessment
determined that “styrene in waste products is not a major pathway for human exposure.”
Despite the apparently very low risk associated with these waste materials, however, two
recent events may have caused (or may yet cause) them to be classified as hazardous:

o In an April 4 Federal Register notice, EPA decided not to add styrene to the list of “hazardous
constituents” in the hazardous waste regulations (Appendix VIII of 40CFR261). EPA had
proposed last year to add styrene to this list as part of a rule regulating paint waste. Adding
styrene to Appendix VIII may have resulted in the classification of many composite industry
wastes as hazardous.

o In an April 19 letter to EPA Administrator Christine Todd Whitman, Senators Barbara Boxer
(D-CA) and Jim Jeffords (I-VT) called on EPA to add styrene and other chemicals to the toxicity
characteristic (TC) list. At present, there are only about 20 chemicals on the TC list, and the
environmental community has long claimed that the brevity of this list is a major shortcoming
of EPA's regulation of toxic waste.

There appears to be no immediate danger that EPA will add styrene to either the list of
hazardous constituents or, despite the Boxer/Jeffords letter, to the toxicity characteristic list.
However, EPA will eventually “reform” the hazardous waste system, and it is likely that
styrene, and consequently many composite industry wastes, will come under increased
scrutiny.

Given the recent and ongoing activity related to styrene, it seems to me that this is a good
time for a review of the rather complex regulations that determine what materials are
regulated as hazardous wastes and how they must be managed once they are.

1. Common questions about waste from composite manufacturing operations

Are overspray and edge-trims hazardous wastes? Generators of waste have the responsibility of
determining if a given waste is hazardous. However, composite manufacturers typically find
that their overspray, edge trims, and similar materials, are neither listed wastes nor
characteristic wastes, and are therefore not hazardous wastes.

Is scrap molding compound hazardous waste? Generators of waste have the responsibility of
determining if a given waste is hazardous. However, composite manufacturers typically find
that scrap molding compounds are neither listed wastes nor characteristic wastes (specifically,
they do not satisfy the criteria in 40 CFR 261.21(a)); and are therefore not hazardous wastes.

Is scrap polyester resin hazardous waste? Generators of waste have the responsibility of
determining if a given waste is hazardous. However, composite manufacturers typically find
that their scrap resins are ignitable (exhibiting a flash point of less than 60 deg. C), and are
therefore hazardous wastes.

When does the scrap resin become hazardous waste? Scrap resin becomes hazardous waste as
soon as the generator forms an intent to discard it.

What if the scrap resin is recycled? Materials that are reclaimed are not considered wastes.
However, the storage and recycling process must take place in a completely closed system (see
40 CFR 261.4(a)(8)). Since this is not typically the case for scrap polyester resins, these
materials are usually considered hazardous wastes even if they are recycled.

Can scrap resins be polymerized and then disposed of as non-hazardous waste? In May of 1997,
EPA approved polymerization ("POLYM") for the treatment of scrap resin, at the site of
generation, without having to obtain a RCRA permit. (Click here to download the relevant
pages of the May 12, 1997 Federal Register Notice approving polymerization for the treatment
of scrap resin). The treatment must occur in tanks, containers or containment buildings, and
these units must comply with the substantive standards set out in 40 CFR 262.34 (standards for
so-called 90-day generator tanks, containers, and containment buildings). A written waste
analysis plan is required, and the amount of scrap resin that is polymerized counts toward the
amount of waste generated monthly. The storage and treatment units should also comply with
the RCRA air emission standards set out in 40 CFR 265 Subpart CC. (Click here for a discussion
on Subpart CC air emission control requirements for storage and polymerization of scrap resin.)
Generators should ensure that the resulting polymerized resin does not itself exhibit the
characteristic of ignitability; many composite manufacturers who use polymerization to treat
resin break open the drums to ensure that no ignitable liquids remain.

2. Federal Definition of Hazardous Waste

Generators of waste answer several questions as they decide if a material is a hazardous waste:
Is the material a "solid waste?" Does it exhibit the "characteristics" of ignitability, corrosivity,
reactivity, or toxicity? Is it a "listed waste?" Is it a mixture that contains a "listed waste?"

Is the material a solid waste? All "garbage, refuse, and sludge" is solid waste. Also, any "solid,
liquid, semi-solid, or contained gaseous material," which is "discarded, served its intended
purpose, or is a manufacturing byproduct" is a solid waste. Composite manufacturers typically
find that their scrap resins, overspray, and other similar materials are solid wastes. See 40 CFR
260 Appendix I Figure 1, and 40 CFR 260.2.

Is the material a hazardous waste? A solid waste is a hazardous waste if it: a) exhibits certain
characteristics, or b) is a listed waste or is a mixture that contains a listed waste. See 40 CFR
Appendix I Figure 2, and 40 CFR 261.3.

Characteristics of hazardous waste

A solid waste is a hazardous waste if it exhibits one or more of the following characteristics:
ignitability, corrosivity, reactivity, or toxicity.

Characteristic of ignitability A solid waste exhibits the characteristic of ignitability if: a) it is a

liquid and has a flash point of less than 60 deg. C; or b) it is not a liquid and is capable, under
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; or c) it is an ignitable compressed gas; or d) it is an oxidizer. Scrap polyester
resins typically have flash points of below 60 deg. C, and so are considered hazardous wastes
because they exhibit the characteristic of ignitability. See 40 CFR 261.21.

Characteristic of corrosivity Few wastes from composite manufacturing operations exhibit the
characteristic of corrosivity. See 40 CFR 261.22.

Characteristic of reactivity Few wastes from composite manufacturing operations exhibit the
characteristic of reactivity. (However, manufacturers needing to dispose of scrap catalysts or
promoters should contact the suppliers of these materials for information on the proper
procedures for doing so.) See 40 CFR 261.23.

Characteristic of toxicity A solid waste exhibits the characteristic of toxicity if, using the
Toxicity Characteristic Leaching Procedure (EPA Test Method 1311), an extract from a
representative sample of the waste contains more than certain amounts of any of certain listed
contaminants (see 40 CFR 264.21 Table 1 for the list of contaminants). Wastes from composite
manufacturing operations typically do not contain sufficient quantities of these contaminants
to be classified as hazardous wastes. Composite manufacturers should review the list of
contaminants for which TCLP testing is required; if they determine that none of these
substances are present in their operations, they can then use "generator knowledge" to
determine that their wastes do not exhibit the characteristic of toxicity and that no TCLP
testing is needed. See 40 CFR 261.24.

Lists of hazardous wastes

40 CFR 261 contains several lengthy lists of substances, manufacturing byproducts, wastes, etc.
Any solid waste that appears on one or more of these lists, or that contains a substance that is
listed, is a listed waste and is therefore a hazardous waste. Composite manufacturing wastes
are typically not listed wastes. See 40 CFR 261.30.

Making the hazardous waste determination

A person who generates a solid waste must determine if the waste is or contains a listed
hazardous waste. If the waste is not a listed hazardous waste and is not a mixture containing a
listed hazardous waste, then the generator must: a) test the waste to determine if it exhibits
the characteristics of ignitability, corrosivity, reactivity, or toxicity; or b) "apply knowledge
[i.e., generator knowledge] of the hazardous characteristic of the waste in light of materials or
processes used." See 40 CFR 262.11.

Generator knowledge Generators can rely on their own knowledge of the "materials or
processes used" to determine if a waste might conceivably exhibit a characteristic. For
example, a generator might review formulations and information provided by suppliers to
determine that a solid waste does not contain any of the substances for which TCLP testing is
required. The generator can rely on this knowledge to determine that the waste does not
exhibit the characteristic of toxicity, without having to perform actual TCLP tests.

Managing hazardous waste

When does a material become waste? As soon as the generator forms an intent to discard a
material, it becomes solid waste. At that time, if the waste is or contains a listed waste, or if it
exhibits the characteristics of ignitability, corrosivity, reactivity, or toxicity, then it also
becomes a hazardous waste, and the generator is subject to the applicable requirements for
waste generators. See 40 CFR 260 Appendix I, Figure 3.

Requirements for waste generators 40 CFR 262 contains several requirements that apply to
generators of hazardous waste, including requirements for obtaining EPA ID numbers (262.12),
manifests (262.20-23), packaging and labeling (262.30-33), limits on accumulation time
(262.34), and record keeping and reporting (262.40-44).

Conditionally exempt small quantity generators A generator is a "conditionally exempt small

quantity generator" in a calendar month if he generates no more than 100kg of hazardous
waste in that month. Conditionally exempt small quantity generators are generally exempt
from the requirements for hazardous waste generators. Be sure to carefully review the
provisions of 40 CFR 261.5.

90-day generators Generators who store ("accumulate") waste on site for 90 days or less prior
to treatment or transport off-site are not required to have permits as treatment, storage, and
disposal (TSD) facilities. 90-day generators, however, are required to store the waste in
containers, tanks, containment buildings, or on drip pads, that meet certain standards, and
must comply with certain requirements for labeling tanks and containers, for testing and
maintenance of equipment, and for contingency planning and emergency procedures. See 40
CFR 262.34.
Requirements for treatment, storage, and disposal facilities

Hazardous waste generators who are not conditionally exempt small quantity generators or 90-
day generators are required to have permits as treatment, storage, and disposal (TSD)
facilities. The Federal regulations that apply to TSD facilities are found in 40 CFR 264 and 40
CFR 265. 90-day generators are allowed to treat hazardous waste in containers without being
permitted as TSD facilities. The requirements for 90-day generators found in 40 CFR 262.34
must be complied with for the treatment operation. In addition, 40 CFR 264 Subparts AA, BB,
and CC contain possibly-applicable standards for the control of organic emissions from
hazardous waste treatment operations.

OSHA Regulation of Hazardous Waste Operations

Generators of hazardous waste must generally comply with the same OSHA regulations that
apply to manufacturers who handle the same materials (for example, compliance with the
applicable Permissible Exposure Limits, the Hazard Communication standard, and the Personal
Protective Equipment standard). In addition, generators who are required to be permitted as
TSD facilities under 40 CFR 264 or 40 CFR 265, and who have emergency response teams that
respond to releases or threats of releases of hazardous waste, must comply with the OSHA
Hazardous Waste Operations (HAZWOPER) standard (29 CFR 1926.65; available from
http://www.access.gpo.gov/ecfr/). Generators who are exempt from TSD permit requirements
must still comply with paragraph (p)(8) of 29 CFR 1926.65.

3. Abbreviations and Links to Federal Documents

CFR = Code of Federal Regulations

References to the CFR are abbreviated in this format: 40 CFR 260.3, which means Title 40, Part
260.3 of the CFR.

To obtain copies of 40 CFR Parts 260-265, which include the EPA hazardous waste regulations,
visit http://www.access.gpo.gov/nara/cfr/waisidx_01/40cfrv22_01.html.

The complete CFR can be obtained from http://www.access.gpo.gov/ecfr/.

FR = Federal Register.

References to the FR are abbreviated in this format: 51 FR 10168, which means Volume 51,
page 10168 of the FR.

For an index to the FR, visit http://www.access.gpo.gov/su_docs/aces/aces140.html.