California waste code 121 Caustic solution at pH 12.5 or below, carrying a listed metal.

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Based on California Title 22 and DTSC guidance
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Inorganics
Alkaline liquid with listed metals

Hazardous alkaline liquid containing a metal listed in code 121; the published pH limits conflict.

Hazardous caustic liquid at pH 12.5 or below, with a metal such as lead, zinc, chrome or copper.

Is California code 121 hazardous waste?

Not from the code alone. The material must first be determined hazardous. California code 121 is not restricted, and a restricted code takes priority over it. A non-restricted code doesn't make a waste non-hazardous.

If the shipment needs the Uniform Hazardous Waste Manifest, enter 121 in Item 13 for the waste line. Use one California code, plus any federal RCRA codes when the waste is federally hazardous.

Waste is RCRA waste when it meets a federal listing or characteristic and no federal exclusion applies. Non-RCRA waste is hazardous under California rules only. California presumes hazardous waste is RCRA unless the generator shows it isn't, so keep that determination.

What does California code 121 cover?

This is for hazardous alkaline liquid holding one or more of the 17 metals named for code 121. The numerical and alphabetical tables give opposite pH limits, so pH alone can't pick the code.

Rule: Appendix XII(b)
Official wording: 22 CCR division 4.5, chapter 11, Appendix XII(b)

Is alkaline metal-bearing liquid California code 121?

Code	When it fits
121	DTSC confirms 121 after reviewing the measured pH and the listed metal.
122	The liquid has no listed metal and a pH above 12.5.
123	The alkaline liquid is hazardous but no more specific alkaline code fits.

The current Appendix XII tables conflict. The numerical table prints pH 12.5 or below, and the alphabetical table prints pH 12.5 or above. Don't pick 121 from pH alone. Confirm the classification with DTSC.

Which wastes take California code 121?

Waste	When it’s 121
Caustic soda solution	An alkaline liquid with a listed metal, once DTSC confirms the disputed pH classification.
Alkaline cleaning solution	An alkaline liquid with a listed metal, once DTSC confirms the disputed pH classification.
Antimony-bearing waste	The alkaline liquid holds antimony, once DTSC confirms the disputed pH classification.
Arsenic-bearing waste	The alkaline liquid holds arsenic, once DTSC confirms the disputed pH classification.
Barium-bearing waste	The alkaline liquid holds barium, once DTSC confirms the disputed pH classification.
Beryllium-bearing waste	The alkaline liquid holds beryllium, once DTSC confirms the disputed pH classification.
Cadmium-bearing waste	The alkaline liquid holds cadmium, once DTSC confirms the disputed pH classification.
Chromium-bearing waste	The alkaline liquid holds chromium, once DTSC confirms the disputed pH classification.

Which codes sit beside California code 121?

Code	What it is
131	Reactive-anion water-based liquid
132	Metal-bearing water-based liquid
133	High-organic water-based liquid
134	Low-organic water-based liquid
135	Other water-based hazardous liquid
141	Unused inorganic material
151	Friable or powdered asbestos
161	Used oil-refinery cracking catalyst