September 9, 2015

Update V to the 3rd Edition of SW–846

EPA publication SW–846, entitled Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, is the agency's official compendium of sampling and analytical methods that have been evaluated and approved for use in complying with the RCRA regulations. The current version of SW–846 (the 3rd Edition) contains 13 chapters of general guidance and over 200 specific methods for the sampling and analysis of wastes.

On August 13, 2015, EPA finalized Update V to the 3rd Edition of SW–846. [80 FR 48522] These revisions contain 23 new and revised analytical methods and reflect modifications to Chapters One through Five of SW–846. Finally, the Office of Resource Conservation and Recovery (ORCR) has added a policy statement regarding the use of SW–846 after the Preface. A few notable items included in the above are:

New methods include 1) mercury species fractionation and quantification, 2) metal cyanide complexes by anion exchange chromatography, and 3) organic compounds in water by microextraction.
References to the method detection limit (MDL) have been removed and replaced with the term “lower limit of quantitation” (LLOQ). Past methods have included MDLs that were, in some cases, unachievable for complex matrices that exist in RCRA wastes. The LLOQ takes into account the effects of not only the matrix, but sample preparations and clean-up methods. In most cases, the LLOQ will be the concentration of the lowest calibration standard in the calibration curve that has been adjusted for the preparation mass and/or volume.
The use of relative standard error may be used as an option (in addition to calculation of the % error) to determine the “goodness of fit” of calibration curves. This change was recommended to the ORCR by the analytical community.

ORCR’s policy statement notes that SW–846 methods should be considered guidance, except for those particular methods referenced in the regulations (e.g., Method 1311 for the TCLP). The office further states “users may select any scientifically appropriate method when conducting analyses to comply with the RCRA regulatory program.”

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This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.