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Safe Handling, Storage, and Destruction of Nitrate-Based Motion Picture Films • H-182 (ENG)
5
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.
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
WASTE MANAGEMENT
AND DESTRUCTION
WASTE CLASSIFICATION
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.
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.
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.
HAZARDOUS WASTE
STORAGE