P-Listed waste is considered to be “acutely toxic” material. This means that the EPA defines it, more or less, as pure waste that is being disposed of. The chemical waste must have come from medication but was a component that wasn’t needed or used.
Two important sectors that frequently deal with P-listed waste are healthcare and pharmaceutical industries, the waste is leftover from medicines or from lab experiments, but the most important distinction is that they are still unused, which means they are still in their original packaging. Waste solvents that are left after an analysis performed in your lab would not count as an example of P-waste. The reason for this is that they were used, even if they were meant to serve as a buffer between other chemicals.
Everything that is on the P-list needs to be tracked as soon as it is categorized as waste. While it is true that there is a cradle-to-grave obligation for all forms of hazardous waste, since this waste is so toxic it needs to be monitored even more closely. All waste generators must abide by this regulation, no matter what industry they belong to, it’s just the right thing to do. There is a fine line between being a small quantity waste generator and a large quantity waste generator, as different levels of oversight will kick in depending on your output.
Separate storage is also important. You don’t want to allow any accidental exposures between materials that shouldn’t mix. Even a tiny bit of cross-contamination turns the otherwise unaffected container into one that should be P-listed, and then it counts towards the amounts that would shift it from low-quantity to high-quantity. By ensuring separate storages, you can make auditing a less difficult process.
All of the P-listed waste at your site needs to be managed separately from all of the other waste. Whether you are preparing it for transport off-site or are determined to dispose of it yourself, this can be a challenge. That’s why there is no shame in relying on help from professionals who know how to do it best. Even containers or packages that no longer hold P-listed waste still need to be treated as if they are right now.
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