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EXHIBIT "A" DSS COMPANY HAZARDOUS WASTE EXPOSURE CONTINGENCY PLAN CAL OSHA STANDARD(29CFR PART 1926, 1100-1148) WHAT IS HAZARDOUS WASTE A waste is considered hazardous if it appears on the lists of hazardous wastes included in federal RCRA regulations [40CFR, §§ 264.30-.33] or as published in the state regulations at 22 CCR § 66261.30 - .33. The state's regulations have been amended in 1991 to include both federal and state lists of hazardous wastes and, herefore, it is not necessary to consult EPA 40 CFR regulations. Wastes have been placed on these lists because they are known to exhibit certain toxicological properties with respect to human health or the environment, are hazardous or dangerous from some other standpoint, or tend to be difficult to store or dispose of effectively. These listed wastes may be from any type of operation and are said to have non-specific sources, generated in the course of certain manufacturing or processing operations. SUMMARY OF HOW TO IDENTIFY HAZARDOUS WASTE To determine whether wastes are hazardous, it will be necessary to study information available on raw materials, have tests performed on your wastes or take other steps to accurately classify the wastes. The following information is provided to help you in making this determination. • If you know the chemical composition of your wastes, check to see if they are listed as hazardous wastes; or • Use information contained on MSDSs to identify the hazardous substances, the operations uses, and which may be contained in its wastes. • If not specifically listed, determine whether your waste exhibits one of the characteristics described above that would qualify it as a hazardous waste. Testing according to the methods by a state-certified laboratory does this. • Check references for typical waste streams and presume that the wastes are hazardous if they fall into these categories. To illustrate: a facility is likely to generate hazardous wastes if it handles the following types of materials and these materials are not entirely consumed by your operations: asbestos cement pipe or asbestos products; oils or other petroleum products; dyes, paints, printing inks, thinners, solvents, or cleaning fluids, pesticides or other related chemicals; materials that dissolve metals, wood paper, or clothing(acids and bases0; flammable materials; materials that burn or itch upon contact with the skin; materials that bubble or fume upon contact with water; products accompanied by shipping papers or labels or an MSDS indicating that the product is hazardous; or any substance listed as a hazardous waste in the list of common names. (Appendix X to 22 CCR §66261, Appendix A) [Reference: California Chamber of Commerce, Hazardous Waste Management Manual, Copyright 01996 by the California Chamber of Commerce]