Discarded Commercial Chemical Products, Off-Specification Species 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, and spill residues. Wastes beginning with a “P” are acutely hazardous wastes (H), and “U” wastes are toxic hazardous wastes (T).
These are the most misunderstood listings because to be listed as a “PU” waste, the chemical:
- must be unused
- must be pure (commercial or technical pure grades, or a sole active ingredient in a formulation)
- cannot have been used or become spent
- cannot have been mixed with other chemicals to form another product
If a waste or an unwanted product contains a chemical on the “PU” lists, it is not automatically a “PU” (stinky) hazardous waste. However, if the PU 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 to be 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-coded, it must be 100% toluene or sole active ingredient.
Activity 3a: Discarded, off-spec, spill residues
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