Hazardous Property (HP) must be properly identified. Your responsibilities include identifying hazardous property as either Hazardous Material (HM) or Hazardous Waste (HW) based upon applicable federal/state/local/foreign country laws and regulations. Hazardous Material (HM) is generally unused, unopened items capable of use as originally intended. If property is identified as HM, stop here and visit the Digital DSR for instructions on turning in property to undergo the RTDS process. Hazardous Waste (HW) is generally used, opened, damaged, contaminated, or expired materials that are no longer capable of being used for their intended purpose without undergoing some type of processing.

• Department of Transportation (DOT) 49 CFR 172.101
• Resource Conservation and Recovery Act (RCRA) 40 CFR 261
• Occupational Safety and Health Administration (OSHA) 29 CFR 1910 Subpart H​

DLA Disposition Services provides disposal services for customers by accepting accountability of HP through a “receipt in place (RIP)” agreement. DoD entities can arrange RIP agreements by using one of the DLA Forms provided below while all non-DoD entities must submit a formal Memorandum of Understanding (MOU). These agreements allow turned-in property to be receipted onto Disposition Services accountable record while staying in physical custody of the generator.

• DLA Form 2542 – RIP Usable, Scrap and Hazardous Material (HM)
• DLA Form 2543 – RIP Hazardous Waste (HW)

DLA Form 2511. Disposition Services customers are encouraged to prepare the HWPS electronically using the automated Hazardous Materials Management System (HMMS). A new HWPS is required from generating activities for each new waste stream. Annual renewal of a HWPS must be accomplished by submitting a replacement HWPS or a certification letter as identified in DoDM 4160.21-V2, Enclosure 7, paragraph 5d(2). A new HWPS is required when an activity’s process change results in changes to the characteristics described on a waste stream’s existing HWPS. Laboratory chemicals, processed in accordance with DoDM 4160.21-V4  are exempt from waste profile requirements; however, all other identification requirements apply (i.e., Safety Data Sheet (SDS)).

Once a HWPS is established for a given waste stream, a Waste Profile Number is generated to identify that HWPS. Future turn-ins of identical waste streams may use the corresponding Waste Profile Number rather than creating a new HWPS. The Waste Profile Number will be identified on the DTID itself.

A HWPS is not required for unopened HW (e.g., expired shelf-life ). However, a Safety Data Sheet (SDS) with all information required for identification of the property is required. If an SDS is not available or indicates the composition is proprietary, a HWPS is required.

Information entered on the HWPS may be based on user's knowledge and/or laboratory analysis of the waste. Supporting documentation may be required if user's knowledge does not identify or characterize the waste sufficiently or correctly. Supporting documentation consists of chemical analysis, description of waste production processes including raw materials, end products, and other sources of how the waste was generated.

(SDS) are an OSHA requirement placed on chemical manufacturers to provide specific information about the chemicals they produce and sell. An SDS is required to accompany all hazardous property when sold or transported. The Hazardous Materials Information Resource System (HMIRS) is the typical mode of providing SDS information during the turn in process. Laboratory analysis may be required if unable to obtain an SDS through HMIRS or by contacting the chemical manufacturer.

Hazardous Material warning labels are required to be attached to individual package or unit container. Generating facilities should become familiar with all federal, state, and local regulations as they pertain to each facility’s specific needs. The following links may be used as a starting point.

• DOT Marking 49 CFR 172 Subpart D
• DOT Labeling 49 CFR 172 Subpart E
• OSHA 29 CFR 1910.1200
• EPA 40 CFR 262 Subpart C

The Department of Defense (DoD) has identified specific property that requires special processing which is subject to unique regulatory constraints because of the nature of the property or its container. Some types of property may be processed for Reutilization, Transfer, Donation or Sale (RTDS) while other property on the list may have to be processed directly to disposal. See disposal guidance in DoDM 4160.21-V4 for hazardous property special processing requirements.