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Differences in DOT and EPA Corrosive Definition [40 CFR 261.22, 49 CFR 173.136] <br />Many people equate the DOT definition of "corrosive" with the EPA's definition of the <br />"corrosivity characteristic" found at 49 CFR 173.136 and 40 CFR 261.22, respectively. That <br />is not correct. <br />The DOT definition deals with liquids and solids that either destroy human skin within a <br />certain time period or corrode steel or aluminum greater than a quarter inch per <br />year. EPA defines corrosive hazardous waste as either liquids that corrode steel greater <br />than a quarter inch per year or aqueous wastes with a pH of 2.0 or less or 12.5 or more. <br />The significance of this? A material can meet the DOT definition of corrosive but not <br />meet the EPA definition of corrosivity, so when shipping a waste of this type, it is not a <br />"hazardous waste" but a Class 8 DOT hazardous material. The word "waste" would not be <br />included in the shipping description of this material, and it would not need to be shipped <br />using the EPA's Uniform Hazardous Waste Manifest. <br />® 9/23/2019 Amazon Confidential 46 EHS <br />