The phrase “Commercial Chemical Product” is used in two critical positions in the hazardous waste regulations of the USEPA.  In either position it may play an important role in your Hazardous Waste Determination which is required by 40 CFR 262.11 for all waste you generate.  The purpose of this article will be to explain the difference in USEPA’s interpretation of this phrase in its two locations and how its interpretation might affect your hazardous waste determination. (more…)