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Mr. Kevin T. Haroff Page 10 0 (b) Pose a substantial present or potential hazard to human health or environment when improperly treated, stored, transported, disposed of, or otherwise managed." Title 22, CCR, Section 66696(a) (6) states that a waste or a material is toxic and hazardous if it: "Has been shown through experience or testing to pose a hazard to human health or environment because of its carcinogenicity, acute toxicity, chronic toxicity, bioaccumulative properties or persistence in the environment." The Wadham ash conforms to the definition of hazardous waste in Section 25117, HSC, because free crystalline silica may cause, or significantly contribute to an increase in mortality or an increase in serious irreversible illness. The ash, therefore, poses a substantial present or potential hazard to human health when improperly treated, stored, transported, disposed of, or otherwise managed. The Wadham ash is hazardous pursuant to Section 66696 (a) (6) , CCR, because free crystalline silica, the principal component of the ash, has been shown through experience and testing to pose a hazard to human health because of its carcinogenicity and chronic toxicity. Crystalline silica is a chemical known to the State of California to cause cancer, and is listed as such pursuant to Proposition 65. The IARC (1987) regards free crystalline silica as presenting a carcinogenic risk to humans based on sufficient evidence of carcinogenicity in animals. Crystalline silica is consequently regulated as a carcinogen by the Occupational Safety and Health Administration (OSHA) . Exposure to materials containing greater than 0. 1 percent crystalline silica are considered to present a carcinogenic hazard (see Title 29, Code of Federal Regulations (CFR) , 1910.1200(d) (5) (ii) ) . Section 66300, CCR, states that all provisions of Title 22, CCR, Division 4, Chapter 30 (Minimum Standards for the Management of Hazardous and Extremely Hazardous Wastes) shall apply to the ,management of any waste which conforms to the definition of hazardous waste in Section 25117, HSC. Section 66305(a) , CCR, further states that a waste must be classified as hazardous if it is within the scope of the Section 66300, CCR, and it is hazardous pursuant to any criterion of Article 11 [e.g. , Section 66696(a) (6) , CCR] or otherwise meets the definition of hazardous waste in Section 25117, HSC. Based on the information contained in Wadham's application, reports from the AIHL, and the relationship between inhalation of silica and chronic disease established by studies cited in this letter and the November 13, 1989 letter, the Department is classifying the ash