♻️ Ley 24.051 · Decree 831/93 · TCLP EPA 1311 · Basel Convention · EPA 40 CFR 261

Hazardous Waste Classification Testing

Before you can manage a waste, you must classify it. A single study can reduce your disposal costs by 5 to 20 times.

In order to decide on the correct final disposal of a waste, it is essential to determine whether it is hazardous or not. Under Argentine Ley 24.051 and Decree 831/93 (Annex IV), a waste is hazardous if it presents at least one of ten defined characteristics. Biogroup has the equipment, methodology and expertise to carry out the complete characterisation study — conforme to both Argentine and international standards.

Many companies pay for hazardous waste disposal year after year without ever having performed the study that could prove their waste is non-hazardous. That analysis has a one-time cost — the savings are permanent.

5 to 20×
Cost difference hazardous vs. non-hazardous
10 characteristics
Evaluated under Ley 24.051
TCLP · EPA 1311
Leachability testing
+35 years
Waste characterisation expertise
⚠️ The default — uninvestigated waste
Classified hazardous by default — paying the maximum cost
Without a classification study, waste must be managed as hazardous by precaution — special transport vehicles, hazardous waste manifests, licensed operators, security landfill or incineration, ongoing insurance and regulatory reporting. Cost: 5 to 20× more than non-hazardous disposal.
✅ The smart approach — classify first
One study — permanent cost reduction
If the study demonstrates the waste is non-hazardous, it can be managed as municipal solid waste — at a fraction of the current cost. The study has a one-time cost that is recovered in the first month of differential disposal. The saving repeats indefinitely.
When is a waste hazardous? — The legal definition under Argentine law
Ley 24.051 / Decree 831/93 — the Argentine hazardous waste law
A waste is classified as hazardous if it presents at least one of the ten characteristics defined in Annex IV of Decree 831/93.

Argentina's hazardous waste framework is established by Ley 24.051 and regulated in detail by Decree 831/93. The classification methodology defined in Annex IV is equivalent in structure to the US EPA RCRA framework (40 CFR Part 261) and the Basel Convention hazard codes — making Argentine waste studies mutually legible with international systems.

The key principle: the absence of a classification study is not a defence. Companies that generate waste and cannot demonstrate it is non-hazardous are legally obligated to manage it as hazardous — with all the associated costs and regulatory requirements.
The 10 hazardous characteristics — Decree 831/93 Annex IV
If a waste presents any one of these characteristics, it is classified as hazardous
Biogroup has the equipment and methodology to evaluate all ten characteristics under the provisions of Decree 831/93 — with additional international method cross-referencing under Basel Convention H-codes and EPA RCRA D/F/K/U lists.
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Inflammability
H3
A waste is flammable if: it is a liquid with a flash point below 60°C; a non-liquid capable of causing fire by friction or contact with moisture; an ignitable compressed gas; or an oxidiser capable of liberating oxygen and sustaining combustion. Determined by closed-cup flash point tester (Pensky-Martens) per ASTM D93.
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Corrosivity
H8
A waste is corrosive if it has pH ≤ 2 or ≥ 12.5 (aqueous solution) or corrodes SAE 1020 steel at a rate greater than 6.35 mm/year at 55°C. Corrosive wastes destroy living tissue and can react dangerously with other materials. Determined by direct pH measurement and corrosion rate test.
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Reactivity
H1 H2
A waste is reactive if it is normally unstable; reacts violently with water; forms explosive mixtures with water; generates toxic gases when mixed with water or acids (e.g. hydrogen sulphide, hydrogen cyanide); is a cyanide or sulphide-bearing waste; is capable of detonation; or is an explosive per DOT classification.
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Toxicity — TCLP
H6.1 H11
A waste is toxic if the TCLP leachate (EPA Method 1311) contains any of the regulated organic or inorganic compounds at concentrations exceeding the TCLP threshold limits. Measures the potential of a waste to contaminate groundwater when placed in a landfill. Full metals suite by ICP-MS and organics by GC-MS.
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Infectiousness / Pathogenicity
H6.2
A waste is pathogenic if it contains viable microorganisms or their toxins at concentrations known to cause disease in humans or animals. Typically applies to medical, hospital and laboratory wastes. Evaluated by microbiological methods.
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Teratogenicity
H10
A waste is teratogenic if it is known to cause non-heritable genetic defects in offspring during foetal development. Classified based on substance content and published toxicological data for known teratogens.
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Mutagenicity
H11
A waste is mutagenic if it is capable of inducing heritable genetic mutations in cells at concentrations that may be encountered under normal conditions of waste management. Classified based on substance content and genotoxicity data.
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Carcinogenicity
H6.1
A waste is carcinogenic if it contains substances classified as IARC Group 1 or 2A carcinogens at concentrations that present a credible exposure risk. Classified based on chemical composition and IARC/EPA cancer classification systems.
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Radioactivity
H12
A waste is radioactive if it emits ionising radiation at levels that present a health risk. Evaluated by radiation survey meter and submitted to CNEA (Argentine Nuclear Regulatory Authority) for formal classification.
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Physical-chemical parameters
H3–H13
Specific measurements required by Decree 831/93 Annex IV: free liquids content, total solids (TS), volatile solids (VS), pH, sulphide content, cyanide content and stabilisation level — the baseline physicochemical characterisation of any solid or semi-solid waste.
TCLP — Toxicity Characteristic Leaching Procedure (EPA Method 1311)
The most technically demanding test in hazardous waste classification
Simulates the leaching of contaminants from a landfill-disposed waste into groundwater — the basis for the toxicity characteristic.
How TCLP works
The waste is extracted with a buffered acetic acid solution (pH 4.93 ± 0.05) for 18 hours in a tumbling extractor. The resulting leachate is then analysed for the full suite of TCLP-regulated metals and organic compounds by ICP-MS and GC-MS. Results are compared against the TCLP regulatory threshold concentrations defined in EPA 40 CFR Part 261.
What TCLP determines
Metals regulated: As · Ba · Cd · Cr · Pb · Hg · Ni · Se · Ag · Zn

Organics regulated: Benzene · chlorobenzene · chloroform · o-cresol/m-cresol/p-cresol · 1,4-dichlorobenzene · 1,2-dichloroethane · 1,1-dichloroethylene · 2,4-dinitrotoluene · hexachlorobenzene · heptachlor · lindane · methoxychlor · nitrobenzene · pentachlorophenol · pyridine · tetrachloroethylene · trichloroethylene · vinyl chloride
TCLP is the cornerstone of waste classification — a waste that passes all physical-chemical tests but fails TCLP on a single metal or organic compound is classified as hazardous (D-code under EPA RCRA, or equivalent under Decree 831/93).
Physical-chemical characterisation — baseline parameters for all waste studies

Before evaluating the hazard characteristics, every waste study begins with basic physicochemical characterisation — the parameters that define the physical nature and chemical composition of the waste matrix.

pH
Acidity/Alkalinity
Direct measurement in aqueous extract or slurry. Trigger for corrosivity classification.
TS
Total Solids
Total residue after drying at 105°C. Determines moisture content and solid fraction.
VS
Volatile Solids
Loss on ignition at 550°C. Proxy for organic content — relevant for biodegradability and biohazard assessment.
FL
Free Liquids
Liquid freely released from the waste under ASTM paint filter test — critical for landfill acceptance.
SL
Stabilisation Level
Degree of fixation achieved in solidification/stabilisation treated wastes. Controls leachate potential.
S²⁻
Sulphides
Free and total sulphide content — trigger for H₂S generation risk when acidified.
CN⁻
Cyanides
Free and total cyanide — trigger for HCN generation risk when acidified.
Flash pt.
Flash Point
Closed-cup method (Pensky-Martens) — trigger for flammability classification at ≤60°C.
International cross-reference — Basel Convention, EPA RCRA and UN GHS
Argentine classification cross-referenced with international frameworks
Basel Convention
Y-codes and H-codes
Waste streams (Y-codes Y1–Y45) and hazard characteristics (H-codes H1–H13) per the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes. Required for international waste shipments, exports and imports under prior notification procedure.
EPA RCRA
D, F, K, U and P lists
US EPA 40 CFR Part 261 hazardous waste lists — D-codes (characteristic wastes: ignitability, corrosivity, reactivity, toxicity), F-codes (listed from non-specific sources), K-codes (industry-specific), U and P codes (discarded commercial chemicals). Cross-referenced in Biogroup reports for clients with US operations or export requirements.
UN GHS
Globally Harmonised System
UN Globally Harmonised System of Classification and Labelling of Chemicals — the basis for waste hazard classification in the EU, China and many other markets. Classification under GHS Annex I hazard categories can be derived from TCLP and physicochemical test data.
The financial impact — what correct classification saves
❌ Waste managed as hazardous (without study)
• Specialised transport vehicle required
• Mandatory hazardous waste manifest per shipment
• Licensed hazardous waste operator and facility
• Security landfill or incineration
• Civil liability insurance obligation
• Permanent records and regulatory reporting
• Frequent regulatory inspections
• Cost: 5 to 20× more than municipal waste
✅ Waste reclassified as non-hazardous (after study)
• Conventional transport — no special requirements
• No hazardous waste manifest required
• Municipal landfill or recycling facility
• No special insurance requirement
• Simplified administrative burden
• Reduced regulatory exposure
• Technically documented before authorities
• Cost: fraction of hazardous disposal cost
The classification study has a one-time cost. If the result demonstrates the waste is non-hazardous, that cost is recovered in the first month of differential disposal — and the saving repeats every month indefinitely.
Waste streams commonly submitted for classification
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Industrial sludges
WWTP sludge · process slurries · filter cakes
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Oil-contaminated waste
Used oils · oily sludge · contaminated absorbents
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Metal finishing waste
Galvanoplating sludge · pickling baths · metal hydroxide slurries
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Chemical waste
Off-spec products · expired chemicals · reaction residues
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Automotive waste
Brake fluid · coolant · paint sludge · solvent wastes
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Agro-industrial residues
Pesticide containers · fumigant residues · crop protection waste
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Construction waste
Contaminated soil · demolition material · PCB-containing materials
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Pharmaceutical waste
Expired drugs · production residues · API waste streams
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Printed matter waste
Ink sludge · developer solutions · printing residues
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Electronic waste
WEEE · circuit boards · batteries · capacitors
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Medical-adjacent waste
Laboratory waste · diagnostic reagents · research chemicals
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Mixed industrial waste
Multi-stream waste requiring classification before disposal contract
What Biogroup delivers

The classification study report is the technical document that supports all subsequent waste management decisions — from negotiating a disposal contract to defending the classification before a regulatory inspector.

Complete analytical results with measurement uncertainty
Comparison against all Decree 831/93 Annex IV thresholds
TCLP leachate analysis — full metals and organics suite
Waste classification conclusion — hazardous or non-hazardous
Applicable Y-codes (Basel Convention waste stream classification)
Cross-reference to EPA D/F/K/U codes where relevant
Hazard characteristics identified (H-codes Basel / Ley 24.051)
Recommended management and final disposal pathway
Chain of custody documentation from sampling to analysis
Report suitable for presentation to SAyDS, OPDS and provincial authorities
Regulatory framework
🇦🇷 Argentine regulations
• Ley 24.051 — Hazardous Waste Law
• Decree 831/93 — Annex II (Tables 1–10) · Annex IV (characteristics)
• Decree 1844/2002 — Province of Santa Fe (Annex II)
• Ley 11.720 — Province of Buenos Aires
• Ley 10.208 — Province of Córdoba
• SAyDS · OPDS — National and provincial authorities
🌐 International standards
• Basel Convention — Y-codes · H-codes · prior notification
• EPA 40 CFR Part 261 — D, F, K, U, P lists
• EPA Method 1311 — TCLP leaching procedure
• ASTM D5765 — TCLP extraction apparatus
• UN GHS — Globally Harmonised System
• ADR / IATA / IMDG — transport classification
Related services
Ley 24.051 · TCLP EPA 1311 · Basel Convention · EPA 40 CFR 261
Is your waste hazardous — or are you paying as if it were?
Contact us to evaluate your waste and define the correct analytical strategy. If the result demonstrates it is non-hazardous, we advise on how to formally reclassify it and make the saving permanent.
Request waste classification →
📞 +54 341 425-6431 📞 +54 341 447-4486 ✉ biogroup@biogroup.com.ar 📍 3 de febrero 920 · Rosario, Argentina Mon–Fri 08:00–17:00