EPA Seeks Tips on Trash Testing Challenges
Published Date: 9/14/2026
Notice
Summary
EPA updates test methods and waste sampling guidance as part of routine updates according to the Resource Conservation and Recovery Act (RCRA). To aid in the implementation of these directives, the Office of Resource Conservation and Recovery (ORCR) within the Environmental Protection Agency (EPA) requests information on SW-846 method experiences, needs, and requirements. ORCR is specifically interested in information on the Toxicity Characteristic Leaching Procedure (TCLP) Method 1311, including method challenges, and alternatives. Information is welcome from stakeholders involved in requesting, performing, and evaluating the results from SW-846 methods including, but not limited to, industry stakeholders, researchers, academia, state, Tribal, and local governments. This includes U.S. territories and the District of Columbia, other federal agencies, community groups, non-governmental organizations, the public, and international organizations. The EPA will use the information received in response to this request for information (RFI) to inform what action, if any, it may take.
Analyzed Economic Effects
5 provisions identified: 3 benefits, 1 costs, 1 mixed.
TCLP (Method 1311) Still Required for Compliance
The Toxicity Characteristic Leaching Procedure (TCLP), SW-846 Method 1311, is currently used for toxicity characteristic hazardous waste determinations under 40 CFR 261.24 and for numeric standards under the Land Disposal Restrictions at 40 CFR 268.48, and must be followed for those regulatory compliance tests.
EPA Considering LEAF as TCLP Alternative
EPA is considering providing a regulatory alternative to TCLP testing using the LEAF methods (SW-846 Methods 1313–1316) for wastes disposed in lined landfills other than municipal solid waste landfills, and is seeking information on how to define testing conditions and on costs and benefits of such an approach.
Method Updates Could Lower Cleanup Costs
EPA notes that analytical methods updates can reduce costs for identification and/or treatment of hazardous waste or for cleanup of contaminated sites, and is requesting information about sampling, testing challenges, and measurable benefits.
Stakeholder RFI — Submit by Nov 13, 2026
EPA is asking for information on SW-846 test methods and waste sampling and will accept comments identified by Docket ID EPA-HQ-OLEM-2026-7360. Comments and information must be received on or before November 13, 2026 to be considered for short-term updates.
LEAF Validated for Inorganics; Organics R&D Underway
EPA states the published LEAF methods (SW-846 Methods 1313–1316) have only been validated for inorganic chemicals, and EPA is conducting research and development to adapt the leaching methods to address organic constituents.
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Key Dates
Department and Agencies
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