Generally hazardous secondary materials can not be distilled without being considered a hazardous waste and requiring shipment on a hazardous waste manifest. By definition, a hazardous secondary material is a waste if distilled prior to use and therefore is still considered a hazardous waste. If distillation is required, then the material must be either shipped to a RCRA Part B permitted facility or shipped to a facility that is under the control of the generator where the hazardous secondary material would be specifically excluded from being a hazardous waste. There are limited other exceptions to this, but in general shipping such a material for recycling will make it a hazardous waste.
Altiras believes that distillation of hazardous secondary materials is one of the top violations of RCRA regulations by brokers and intermediaries who either don’t understand the regulations or willfully violate them, unbeknownst to the generators of the materials they serve.