Frequent Questions

Do the P and U lists apply to chemicals that have been used in a manufacturing process?

The P and U lists apply only to commercial chemical products (CCPs), off-specification species, container residues, and spill residues from chemicals having the generic name listed in Section 261.33. Commercial chemical products do not refer to a material, such as a process waste, that contains any of the substances listed in Sections 261.33(e) or 261.33 (f). To be considered a hazardous waste, such process wastes must be isted in either Section 361.31 or 261.32 or be identified as a hazardous waste by the characteristics in Sections 261.20 thru 261.24. Commercial chemical products are chemical substances manufactured or formulated for commercial or manufacturing use that consist of the commercially pure grade of the chemical, any technical grades of the chemical that are produced or marketed, and all formulations in which the chemical is the sole active ingredient (Section 261.33(d)). The P and U lists do not apply to chemicals that have been used for their intended purpose (54 FR 31335, 31336; July 28, 1989). 

Additional information may be found at: 
Memo, Carson to Bassell; May 14, 1985 (RCRA Online #11076)
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