A.  Saccharin was identified by EPA’s Carcinogen Assessment Group as a potential human carcinogen.  This lead to its inclusion on EPA’s list of hazardous constituents (40 CFR Part 261Appendix VIII) and, as a result, list of hazardous wastes (EPA Hazardous Waste No. U202 in 40 CFR 261.33(f)) in May 1980.  The Agency added “and salts” to the saccharin listing in November 1980, since normal commercial use includes both forms.  The substances listed on 40 CFR 261.33(f) are commercial chemical products, manufacturing chemical intermediates, or off-specification commercial chemical products that are hazardous wastes if and when they are discarded or intended to be discarded.

EPA’s listing of saccharin and its salts as hazardous substances under 40 CFR 302.4 is based solely upon these substances being listed as U202 hazardous wastes under 40 CFR 261.33(f)).