From:Gary Jones (firstname.lastname@example.org )
Date:Thu, 7 Feb 2002 22:13:17
There are no specific regulations governing the classification and disposal of toner cartridges. Like any other waste stream generated at the facility, they need to be evaluated relative to the hazardous and solid waste regulations to determine if they are hazardous or nonhazardous wastes. Hazardous wastes need to be managed and disposed according to a specific set of rules, while solid wastes can typically be disposed in the general solid waste stream.
In evaluating the status of the toner cartridges relative to the hazardous waste regulations, the first issue is the amount of toner that is remaining in the cartridge. If the cartridge is full, then a determination of the toner needs to be completed. This can be accomplished by either "application of knowledge" or testing. Since toner vendors are reluctant to reveal the composition of toner, testing may be the only real option. I would contact the vendor to see of they have ever conducted testing, specifically TCLP testing on their toners and have them provide a copy.
If the cartridge is empty, even if the toner is hazardous, they can be disposed as "empty containers" in the general solid waste stream. EPA allows for a small amount of hazardous waste to be in a container as long as it meets specific requirements. The requirements are:
A container or an inner liner removed from a container that has held any hazardous waste is empty if:
(1) All wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating, and
(3) No more than 3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is less than or equal to 110 gallons in size.
Therefore, if the cartridge contained 1 pound of toner, then if 0.03 pounds or less is present in it, then the container is considered empty. If you contact the vendor and/or conduct TCLP testing, I would be interested in receiving a copy of the data as I don't have any of this data.