Waste codes
D041: 2,4,5-Trichlorophenol
The toxicity characteristic code for 2,4,5-trichlorophenol. Regulatory level 400.0 mg/L by TCLP.
D041 is the RCRA waste code for waste that fails the toxicity characteristic for 2,4,5-trichlorophenol. A waste carries D041 when the Toxicity Characteristic Leaching Procedure extract contains 400.0 mg/L or more of 2,4,5-trichlorophenol.
Source: 40 CFR 261.24, Table 1Where D041 waste comes from
The streams that most often carry D041 in Southeast industry:
- Biocide and preservative manufacturing
- Herbicide intermediate production
- Wood treatment formulations
If you generate a 2,4,5-trichlorophenol bearing stream
The practical question is rarely whether 2,4,5-trichlorophenol is present. It is whether enough of it leaches out under the TCLP to cross 400.0 mg/L. Two plants running the same process can land on opposite sides of that line depending on the matrix the waste sits in, so the determination is made per stream rather than per industry.
That matters commercially as well as legally. A stream that passes is managed as non-hazardous at a fraction of the cost, and a stream that fails carries D041 from the moment it is generated, not from the moment it is tested. Where the result sits close to the threshold, it is worth retesting when the process changes.
If you are working with biocide and preservative manufacturing and have not characterized the waste, that is the place to start. Send what you have and a Certified Hazardous Materials Manager will tell you whether testing is needed or whether process knowledge already settles it.
How the determination is made
A generator must determine whether a waste is hazardous under 40 CFR 262.11. For D041 that means either testing by TCLP or applying knowledge of the process.
- TCLP extraction under SW-846 Method 1311, analyzed for 2,4,5-trichlorophenol
- Regulatory level for comparison: 400.0 mg/L
- Process knowledge is acceptable where the input materials and process are documented
- Testing settles the question. Guessing at a code is how a load gets rejected
- The determination and its basis are retained for three years under 40 CFR 262.40
How D041 waste is treated
High temperature incineration with dioxin controls
See hazardous waste disposalCommon questions
What is the regulatory level for D041?
400.0 mg/L of 2,4,5-trichlorophenol in the TCLP extract. At or above that concentration the waste carries D041 and is regulated as hazardous from the point of generation. The full table is at 40 CFR 261.24.
Does total 2,4,5-trichlorophenol content decide whether my waste is D041?
No. The toxicity characteristic is based on what leaches out under the TCLP, not on total concentration. A waste can hold a high total concentration and still pass, and the reverse is possible where the matrix releases readily.
Can D041 waste go straight to landfill?
Not untreated. Land disposal restrictions at 40 CFR Part 268 require the waste to meet a treatment standard before land disposal, and a land disposal restriction notification travels with every shipment.
Is D041 the only code my waste carries?
Often not. A stream can fail more than one characteristic and can also be listed. Every applicable code goes on the manifest, and the most stringent treatment standard governs how the waste is handled.
Who decides my waste is D041?
You do. The duty to determine sits with the generator under 40 CFR 262.11, not with the transporter or the receiving facility. Greer will characterize the stream and assign codes, but the determination remains yours to make and to document.
Related services
Not sure how this applies to your stream?
Send a profile, an old manifest, or photographs of the drums. A technical professional will tell you what you are holding.
This page summarizes federal requirements and is not legal advice. State programs can be more stringent than the federal baseline. Verify against current federal and state regulations before acting. Last reviewed September 2026.