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Q&A: Do I have a P-Listed Hazardous Waste?

Q&A: Do I have a P-Listed Hazardous Waste?

A Question (way back on February 16th) requesting help with the annual hazardous waste report (Due March 1st!):

I am completing the annual hazardous waste report and am trying to determine whether the material is non-acute or acute. Hopefully you can answer my question and offer a bit more information.

Looking through the forms, I think we are P042.

This may be all I need, however; I would appreciate any articles you may share with me.

I also spoke with this person over the phone to gather additional information.  The inquisitor referred to “epi pins” that they discard as a waste.

My answer a few hours later that same day (I knew she was in a rush for the information):

I apologize for my delay, my return to the office took longer than I thought.  Your situation calls for more research but I will do my best to answer your question and direct you to additional information.

Excerpt from the USEPA List of Lists

  • In addition to being listed by name the material must also be one of the below.  Also, read What is a P- or U-Listed Hazardous Waste?
    • Unused or virgin, or;
    • An intermediate product you manufactured, or;
    • An off-spec version of a listed material, or;
    • Residue in a container that is not “RCRA Empty”, or;
    • Residue or recovered spilled material.
  • Any P-Listed hazardous waste is also known as an acute hazardous waste.  Read: What is an Acute Hazardous Waste?

If the “epi pins” you mentioned meet the above criteria, it is likely you are a generator of an acute hazardous waste and likely a Large Quantity Generator (LQG).  Read:  Determine Hazardous Waste Generator Status From Acute Hazardous Waste.

Further questions:
  • Are you the generator of this waste?  If you are gathering this waste from others, then it is possible that you are not the generator of the waste; the ones sending it to you are the generators.
  • Who are the “persons” sending you the waste?  If they are excluded or exempt from regulation, e.g. a household, it is likely the waste is excluded as well and therefore not subject to reporting.
  • If the “persons” sending you the waste are not excluded from regulation, how are they sending it you?  Hazardous waste is not usually sent by mail.
  • There are other hazardous wastes, both listed and characteristic, associated with medical or pharmaceutical waste.  Do you have other hazardous waste to report?
  • If not an excluded hazardous waste is it being managed according to the RCRA regulations (state and federal) applicable to a Large Quantity Generator?  Requirements include:  annual training (I do this!), weekly inspections, emergency preparedness, a Contingency Plan, closed containers labeled and marked, 90 day on-site accumulation time limit, more…
I can help you out with any questions you may have about the regulations for waste management and the transportation of hazardous materials.

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services




I didn’t hear from the person after that.  I only hope my answer was of some help.