P-Listed (Acutely Toxic) Chemical Waste

The United States Environmental Protection Agency (EPA) has established additional removal, disposal, and reporting requirements for P-listed (acutely hazardous) chemical wastes. UT Dallas, in seeking to fully comply with these regulations, has developed several guidelines for laboratories when dealing with P-listed chemical wastes.

A quick guide for P-Listed Chemicals is available here.

Identifying P-Listed Chemical Wastes

P-listed chemical containers should be identified by a green sticker, provided by Research and Academic Safety. P-listed chemical waste does not include waste that was generated from an experiment UNLESS the listed chemical was unused, spilled, or leaves a residue. P-listed waste includes only:

  • Discarded commercial chemical products
  • Off-specification species
  • Container residues
  • Spill residues

If you are unsure if a waste is P-listed, ask your Safety Specialist or email waste@utdallas.edu. The EPA maintains a list of P-listed chemicals in 40 CFR 261.33, also viewable as a searchable PDF here. Wastes are first listed in alphabetical order by chemical name and then listed again in numerical order by CAS number. Rows that are highlighted yellow are P-listed chemicals that the EPA has designated as “reactive acutely hazardous material.” These have additional requirements under Subpart K, and you will be contacted by Research and Academic Safety if your lab acquires any of this material. These six chemicals are:

  • Aluminum phosphide
  • Ammonium picrate
  • Mercury fulminate
  • Nitroglycerine
  • Tetranitromethane
  • Zinc phosphide (>10%)

Handling P-Listed Chemical Waste

P-listed chemical containers should not be rinsed, re-used, or discarded in a trash or recycling bin. Instead, submit a Laboratory Chemical Cleanout Request form. This form will allow a quick entry list of up to 20 containers. You do not need to remove UT Dallas barcodes, or affix waste tags to these containers.