Waste Management and Destruction

Cellulose nitrate films that have reached the third stage of decomposition, or have no historical value, need to be destroyed properly. Since these films decompose rapidly under certain conditions and are flammable, it is important that you store and transport these materials safely.

WASTE CLASSIFICATION

Once it is determined that a cellulose nitrate film needs to be destroyed, it is considered a waste. Under the Resource Conservation and Recovery Act (RCRA), all waste cellulose nitrate films should be classified as hazardous wastes. Cellulose nitrate film that is designated for destruction must be identified as a hazardous waste using all applicable Environmental Protection Agency (EPA) Waste Codes. The

following EPA Waste Codes may apply to cellulose nitrate film:

Stable cellulose nitrate films designated for destruction or those that are in one of the first two stages of decomposition should be classified as a hazardous waste using EPA Hazardous Waste Codes D001 and D003. Cellulose nitrate films that are in one of the last three stages of decomposition should be classified as a hazardous waste using EPA Hazardous Waste Codes D001, D003, and D011.

HAZARDOUS WASTE

STORAGE

All cellulose nitrate films that are marked for destruction need to be stored and transported under water.

You will need to place them in a steel or plastic drum that meets US DOT specifications, and cover the films with water. The water must be more than 25 percent by weight of the total weight of the films. (Water weighs about 8 pounds per gallon.) Be sure to take into account the weight of any film reels.

When a cellulose nitrate-based film is designated for destruction, and is, therefore, a hazardous waste, RCRA requirements may apply to your storage facility. Long-term storage may require a RCRA permit. When a cellulose nitrate- based film is determined to be a hazardous waste, you should send it to an authorized waste-treatment facility for proper destruction as soon as possible.

EPA Waste Code	Definition

D001	A material is defined as an ignitable hazardous waste if it
	is an oxidizer as defined under USDOT regulations. Nitrate
	containing materials are specifically defined as oxidizers
	under those provisions.

D003	A material is defined as a reactive hazardous waste if it is
	capable of detonation or explosive reaction when subjected
	to a strong initiating source or heated under confinement.
	Cellulose nitrate films meet this criteria; they will spontane-
	ously ignite under elevated temperatures. The rate of
	combustion of nitrate films is about fifteen times that of
	wood, and the resulting intense fire is virtually impossible to
	control or easily extinguish.

D011	A material is defined as a hazardous waste possessing the
	characteristic of leachable toxicity for silver if, when
	exposed to the Toxicity Characteristic Leaching Procedure
	(TCLP), the material leaches > 5 mg/l (ppm) of silver.
	Typically photographic films do not leach > 5 mg/l of silver
	when subjected to the TCLP. However, during decomposi-
	tion, it is likely that more silver may be present during
	leaching once the film has reached the third stage of
	decomposition. The TCLP can also be performed on a
	representative sample of a film to define its characteristics.

Safe Handling, Storage, and Destruction of Nitrate-Based Motion Picture Films • H-182 (ENG)

H-182 (ENG)2 specifications

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