EPA`s draft Technical Background Documents on Associated Waste (1995) suggested that there are serious concerns about landspreading and roadspreading practices used by the oil and gas production industry. The TCLP was among the criteria EPA used to evaluate the hazard posed by associated wastes. However, the TCLP and EPA`s regulatory models do not appropriately characterize E&P waste disposal practices or the fate and transport of organic compounds such as benzene.