In 1991, in response to the Department of Energy (DOE) Moratorium on the shipment of hazardous waste from Radioactive Materials Management Areas (RMMAs), Lawrence Livermore National Laboratory (LLNL) developed a process to use a combination of generator knowledge and/or sampling and analyses to certify waste as non-radioactive. The analytical process used the minimum detectable activity (MDA) as the de minimus value. In the past twelve years, a great deal of operating experience has shown the LLNL certification process has serious limitations including: (1) Procedure-specified analytical methodologies have resulted in the inability to adopt new techniques and methods that are more rapid, safer, and produce less waste. (2) The characterization of materials as radioactive or non-radioactive is dependent on method-specific detection limits, not on an objective risk-based standard. (3) There are substantial differences in the limits for surface contamination, sewer discharges, and hazardous waste moratorium determinations, even though all of these methods are used to free-release materials from radiological controls. LLNL, in conjunction with the Chamberlain Group and Dade Moeller & Associates, Inc., is pursuing a risk-based approach to determine whether waste is non-radioactive, consistent with DOE guidance. This paper discusses the approach, which includes defining the radionuclides considered, establishing the exposure scenarios for the critical groups identified for each of three waste streams, defining the exposure pathways and key input data or assumptions, presenting radiation doses for unit concentrations of radionuclides in each waste stream, presenting radiation doses for unit concentrations of radionuclides in each waste stream, presenting the authorized limits for each waste stream, and discussing the results. Analytical values which fall below these authorization limits will be considered non-radioactive, with any individual dose maintained below 1 mrem/yr.