Is Your Solid Waste a Listed Waste?
EPA's four types of listed hazardous wastes include;
F-listed wastes: The F list includes wastes from common industrial
processes. Because they are not specific to one type of industry, they are
called wastes from non-specific sources. This list includes for example many
types of spent (or used) solvents. See 40 CFR 261.31 to see if your waste is
K-listed wastes: The K list includes wastes from specific industrial
processes, such as wood preservation, organic chemical production, and
pesticide manufacturing. See 40 CFR 261.32 for the complete list of
manufacturing process wastes to see if your facility might have a K-listed
P- and U-listed wastes: These two lists designate certain commercial
chemical products as hazardous when disposed of unused. These unused
chemicals may become wastes in a number of ways. Some can be spilled while
in use, while others can be intentionally discarded if out of specification.
For waste to qualify as a P or U listed waste, it must meet all three of the
following criteria: The formulation must contain at least one chemical on
the P or U list. The chemical in the waste must be unused and the chemical
in the waste must be in the form of a commercial chemical product (CCP),
which is a chemical that is of technical (commercial) grade, 100% pure, and
the only active ingredient in the formulation.
There are hundreds of P- and U-listed wastes in
40 CFR 261.33. Chemicals with the "P" code are acutely hazardous. P
chemicals posses extremely hazardous properties, which makes the chemicals
lethal in very small quantities. Generators with acutely hazardous waste are
subject to different accumulation limits for P wastes. If a facility
generates a single P waste at a rate greater than 1 kg/month, the facility
is regulated as a large quantity generator (LQG). The U list chemicals are
regulated at a regulatory threshold of 100 kg/month. A facility generating a
U listed waste greater than 100 kg/month to 1000 kg/month is regulated as a
small quantity generator (SQG).
U- Listed wastes are generally the result of a spills/leaks or disposal of
pure chemical, such as acrylamide, acrylic acid, formaldehyde, methanol,
ethylene dichloride, methyl chloride, and methyl methacrylate to name few.
A simple method to help make a determination on whether a material is a
listed is by examining the container's label. If the container's label uses
one of the generic chemical names from the list to describe the contents of
the container, the material is a listed waste. However if the label does not
use a name or term on the P or U-list, the material is probably not listed.)
Waste generated during either storage or transfer of a CCP (P or U listed)
before entering the first step of a manufacturing process will carry the
associated P or U listed code. Once a P or U listed CCP is in the
manufacturing process any subsequently generated process wastes will not
carry the P or U listing. The process waste generated may be a K or F listed
waste or a D characteristic waste.
Is the solid waste a listed waste (F, K, P, or U waste)?
If YES - the waste is a listed and subsequently regulated under RCRA
If NO - go to Characteristic Waste Page