When Are Unused Chemicals Hazardous Waste? (P and U List)

Описание: This video explains how to identify chemical products regulated as hazardous waste under RCRA and listed on the P- and U- List in 40 CFR 261.33, and how to assign to right RCRA P- or U- code to a hazardous waste. The P- and U-List is a list of commercial chemical products or CCPs that are hazardous waste when discarded. The list includes many common solvents, known carcinogens, pesticides, poisons, and chemicals that are bioaccumulative (meaning they build up in the human body or the environment over time).

Free Cheat Sheet—RCRA Waste Codes: https://www.lion.com/cheat-sheet-009-...

🎥 IN THIS VIDEO:
🛢️ Used vs. unused chemicals as waste under RCRA 0:28
🛢️ The RCRA P- and U-List Explained 1:16
🛢️ Definition of a "commercial chemical product" under RCRA 1:43
🛢️ "Active ingredient" vs. "Inactive ingredients" for chemicals 2:10
🛢️ Understanding "sole active ingredient" under RCRA 2:55
🛢️ P-code hazardous waste vs. U-code hazardous waste
🛢️ Definition of "acute hazardous waste" under RCRA 3:45
🛢️ Examples of "P-listed" waste—incl. some common solvents, poisons, pesticides, et. al. 3:50
🛢️ Examples of "U-listed" wastes—incl. acetone, methylene chloride, vinyl chloride, et. al. 4:00
🛢️ Format of the RCRA P- and U-List/RCRA hazard codes (I, C, R, T) 4:15
🛢️ Recap of key insights for hazardous waste generators 5:00

When you use hazardous chemicals, you sometimes create hazardous waste. We've discussed F-List and K-List hazardous wastes on this channel previously: These are wastes like spent solvents, sludges, tank residues, wastewaters, and others generated by or put through some type of industrial or commercial process. The F-List and K-list, in other words, are for chemicals that have been used.

What about chemical products that have NOT been used, but that, for one reason or another, someone still wants to get rid of? Are expired chemicals hazardous waste, for example? What about unused chemicals that are waste because they are off-specification and can’t be used? What about unused chemicals that are waste because they spilled?

The RCRA P- and U-List, found at 40 CFR 261.33, is a list of "commercial chemical products" or CCPs that are regulated hazardous waste under Federal law when they are discarded.

Under RCRA, "Commercial Chemical Product (CCP)" means any pure grade or technical grade of a listed chemical, as well as formulations with the listed chemical as the sole active ingredient. The definition also covers off-spec chemicals, residues from containers, and contaminated soil, water, or debris from spill cleanup.

RCRA "P Code" vs. "U Code" Hazardous Waste
🛢️ P-codes are assigned to wastes that that are acutely hazardous, meaning they can kill or irreversibly harm humans or animals in low doses. That includes some of the poisons and pesticides on the list, like aldrin, methomyl, nicotine, and potassium cyanide.

🛢️ Everything else on this list is a “non-acutely” hazardous waste and gets a U Code, including chemicals like acetone, benzene, formaldehyde, hydrogen sulfide, methylene chloride, toluene, vinyl chloride, xylene, and many others.

Understanding the phrase “sole active ingredient” is key to assigning the right P or U code. Because while it’s possible you have a 100% pure grade chemical on your hands, many, many chemical products are formulations that combine different ingredients for different purposes.

The “active ingredient” in a product is the ingredient included to accomplish the product’s purpose.
In a pesticide, for example, the “active ingredient” is what kills the pest. In a cleaning product, the “active ingredient” is what cleans a surface.

Inactive ingredients are there for a reason too—just not the main reason—they might improve the product’s shelf-life, make the product colorful or make it smell nice, or bind together the other ingredients.

Some chemical products have more than one active ingredient—a lot of solvent blends, for example, combine several chemicals that are ALL utilized for their cleaning or degreasing abilities. When a product has more than one active ingredient, even if all those active ingredients are listed on the P and U List, the generator does NOT assign a P or U code to that waste according to the FEDERAL RCRA regulations.

🛢️ Free RCRA Resources 🛢️

"RCRA Hazardous Waste Codes Cheat Sheet"
https://www.lion.com/cheat-sheet-009-...
This 1-page guide to RCRA hazardous waste codes describes the major RCRA lists—the F-List, K-List, and P- and U-List, and explains how generators use the codes on these lists to accurately identify regulated waste, communicate hazards, and ensure proper treatment, recycling, and/or disposal to comply with RCRA Land Disposal Restrictions (LDRs).