What Are EPA RCRA Listed Wastes?

Listed Wastes

If you work in the healthcare environment, you know that you must carefully dispose of hazardous waste. First, you must decide if the waste that you are managing is a hazardous waste (HW), and then you must make certain that you dispose of the HW properly.  With so many types of hazardous waste, it can get confusing. This blog will discuss the types of listed hazardous wastes found in healthcare, with an emphasis on hazardous waste pharmaceuticals (HWP), the most common type managed in healthcare.

EPA Hazardous Waste:

  • Hazardous Waste is waste that is dangerous or potentially harmful to our health or the environment and is defined by the EPA.1
  • Hazardous wastes can be liquids, solids, gases, or sludges.
  • Listed Wastes are wastes that EPA has determined are hazardous.
  • F-list: Wastes from common manufacturing and industrial processes
  • K-list: Wastes from specific industries
  • P- and U-lists: Wastes from commercial chemical products

P- and U-Listed Wastes

P- and U-listed wastes are “unused commercial chemicals”2 that are being disposed, such as chemicals that are expired or spilled and were then cleaned up.  The main difference between P- and U-Listed wastes is their level of risk. U-listed wastes are considered “toxic” but not as toxic as P-listed wastes.3 There are several pharmaceuticals that are classified as either P-listed or U-listed HWPs.

P-Listed Waste: Acute Hazardous Waste

  • Acute hazardous waste exerts its toxicity with exposure to smaller quantities and in a shorter time period
  • Empty containers regulated as hazardous waste
  • Examples: Warfarin, Physostigmine, Nicotine, Arsenic Trioxide, and their packagings

U-Listed Waste: “Toxic”

  • “Discarded products” or mixtures containing at least 10% of these U-listed materials
  • Empty containers are not regulated as HW
  • Examples: Cepastat Lozenges, Chloraseptic Spray, Reserpine, and Selenium Sulfide

F- and K-Listed Wastes

F- and K-lists contain process wastes, which are “wastes generated from processes carried out in a facility.”4  There are very few times that you will see an F-listed waste (wastes from non-specific sources) in healthcare. You will never have a K-listed waste (source-specific wastes) because they are from specific industrial processes.

F-listed Waste

In the healthcare industry, only solvent waste from a process or procedure could be an F-listed waste.  These types of wastes are typically generated in diagnostic labs and would be of these types:

  • F003: Spent non-halogenated solvents, such as xylene, acetone, ethyl acetate, n-butyl alcohol, cyclohexanone, and methanol
  • F005: Spent non-halogenated solvents, such as toluene, isobutanol, and benzene

The F-listed designation can be a bit tricky, so please contact Sharps Compliance to assist you with this determination.

1 Hazardous Waste Defined

2 Is it listed?

3 See FN 3.

4 See FN 3.

Joe Jordan

Joe Jordan

Director of Hazardous Waste Solutions at Sharps Compliance
Joe Jordan has a Bachelors of Arts degree in Chemistry from Washington and Jefferson College. He is certified in RCRA & DOT, as well as 40 Hour HAZWOPER certified. Joe has been in the hazardous waste industry since 1990 and has managed industrial, healthcare, retail & governmental clients both large & small.
Joe Jordan

Author: Joe Jordan

Joe Jordan has a Bachelors of Arts degree in Chemistry from Washington and Jefferson College. He is certified in RCRA & DOT, as well as 40 Hour HAZWOPER certified. Joe has been in the hazardous waste industry since 1990 and has managed industrial, healthcare, retail & governmental clients both large & small.