Discarded Commercial Chemical Products, Off-Specification Species, Container Residues and Spill Residues

Codes beginning with a “P” or “U” followed by a three digit number (e.g., P001 or U001) designate discarded commercial chemical products, off-specification species, container residues and spill residues¹. 

These are the most misunderstood listings because to be listed as a “P or U” waste, the chemical:

• must be unused, cannot have been used or become spent
• must be pure (commercial or technical pure grades, or a sole active ingredient in a formulation), cannot have been mixed with other chemicals to form another product

If a waste or an unwanted product contains a chemical on the “P or U” lists, it is not automatically a “P or U” hazardous waste. However, if the P or U listed chemical spills and residues are cleaned up, the spill residues carry the P or U listing of hazardous waste.

Example: Discarded Commercial Chemical Products (U220) – Toluene

In order for toluene to be a U220 listed waste, it must be in a technical grade, unused and discarded. Toluene, as an ingredient in a paint formulation would not meet the U220 listing, even if the paint contained 50% toluene because it is not the sole active ingredient in the paint formulation. The pigment in the paint is another key ingredient in paint. For the waste to be U-listed, it must be 100% toluene or sole active ingredient.

Once a RCRA listed hazardous waste always a RCRA listed hazardous waste.

Activity 3a: Discarded, off-spec, spill residues

Question:

Several of the wastes below are P or U wastes. Which of these can be a P or U waste?

References

¹22 CCR section 66261.33