Not Paperwork — Liability Protection
An incorrect waste code isn't a clerical mistake. It's a compliance violation that can trigger rejected loads, return shipments at the generator's expense, enforcement action, and personal liability for signers on the manifest. The determination is the legal foundation of everything that happens after — and getting it wrong has consequences that don't surface until months later when an inspector is reading your file.
The Actual Analysis
Evaluation for D-code characteristics (ignitability, corrosivity, reactivity, toxicity) and listed waste applicability.
Systematic review of every applicable code category. F-codes for listed solvents. U/P codes for discarded commercial chemical products.
We identify when sampling is necessary, coordinate the lab work, and interpret the results. Many streams don't require TCLP — we won't run analysis you don't need.
Land Disposal Restriction review — what treatment standards apply and what certifications the manifest requires.
Texas has state-specific classifications (Class 1, 2, 3) layered on top of federal RCRA. We navigate both.
Memo of determination available on request — the document you want in your file when TCEQ knocks.
How We Actually Do It
- SDS ReviewWe start with the safety data sheets for every input that could be in the waste. This alone resolves many determinations.
- Process Knowledge InterviewShort conversation with the operator who actually generates the waste. What goes in? What reacts? What accumulates?
- Sampling (If Needed)When SDS and process knowledge aren't sufficient — usually for contaminated soils, mixed aqueous streams, or unknowns — we arrange analytical testing.
- Written DeterminationFinal waste codes documented in a memo suitable for your compliance file.
The Form Everyone Hates
Every TSD facility requires a waste profile — a detailed characterization document that they review before accepting your waste. Most generators find the forms confusing, time-consuming, and re-work-prone. We fill them out every day; we know which sections matter, which pitfalls cause rejection, and how the receiving TSDF will actually read what you submit.