Frequent Questions

Do the P or U waste codes apply to any discarded commercial chemical product (CCP) containing the substances listed in 40 CFR §261.33?

The P or U waste codes apply only if one of the listed chemicals is discarded unused.  In addition, the chemical must be present in a pure or technical grade form, or be the sole active ingredient in the chemical formulation (§261.33(d))(54 FR 31335, 31336; July 28, 1989).  The pure form of a chemical is a formulation consisting of one hundred percent of that chemical.  The technical grade of a chemical is a formulation in which the chemical is almost one hundred percent pure but contains minor impurities (Memo, Lowrance to Wayland; May 3, 1988; RCRA Online 11348) [PDF 6K].  A chemical is the sole active ingredient in a formulation if that chemical is the only ingredient serving the function of the formulation.  If a formulation contains more than one active ingredient, the formulation would not be within the scope of the P and U listings in §261.33, regardless of whether only one or both of the active ingredients are listed (Monthly Call Center Report Question; March 1992; RCRA Online 13530). 

Additional guidance regarding the applicability of P and U listed waste codes is available in the following documents: Monthly Call Center Report Question; August 1996 (RCRA Online14012)
Memo, Barnes to Mastalerz; April 21, 1989 (RCRA Online 11459)
Memo, Barnes to Fox; May 19, 1988 (RCRA Online 11350)

Have more questions? Submit a request