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P2 | Steps to Determine a Business’s Eligibility

Pollution Prevention (P2) Program

Determining a Business’s Eligibility

Revised On: Nov. 22, 2023 - 9:20 a.m.

In an effort to prevent pollution (P2), more businesses are adopting measures that go beyond minimum standards set by regulations. We assist these organizations by providing guidance to achieve successful P2 measures. Following is a list of steps and resources to help determine your business’s eligibility for the P2 Program.

Step 1

Review Filing Thresholds to Determine If Your Company Needs to Submit a P2 Plan

Filing a P2 Plan is required for businesses that exceed any of the thresholds for hazardous waste generation and toxic substance use. If the facility does not meet any of the thresholds, a P2 Plan can be filed voluntarily. The P2 thresholds are as follows:

  • During the preceding calendar year, the owner or operator was required to file an annual toxic chemical release (Environmental Protection Agency [EPA] Toxics Release Inventory [TRI]) form (Form A or Form R) for the facility.
  • During the preceding calendar year, the facility generated an average of 1 kilogram per month of acutely hazardous waste or an average of 1,000 kilograms per month of hazardous waste in a calendar year, exclusive of an episodic, accidental or remediation related release or occurrence.
  • A facility that uses in excess of 10,000 pounds in a calendar year of a toxic substance, as defined in ARS § 49-961. Please visit the EPA TRI for a list of toxic substances (chemicals and chemical categories).

If your facility meets one of the above thresholds, proceed to Step 2.

Step 2

Review P2 Filing Exemptions

Even if your business exceeds threshold requirements, a P2 Plan is not required if the facility meets any of the exemptions. If the facility is exempt, a P2 Plan may still be voluntarily submitted | View/Download P2 Planning Exemptions > 

  • For sand and gravel, ready-mix concrete, hot-mix asphalt or cement production facilities, review the “Mining Operations Exempt from Pollution Prevention Plan Policy” | View/Download > 
  • For clarification on the definition of metallurgical exemption, review the “Metallurgical Policy” | View/Download > 
  • For clarification on the definition of use, review the Interpretation of “use” of toxic substances in excess of 10,000 pounds for the Pollution Prevention Program | View/Download > 

Step 3

Use the Threshold Screening Tool

Use the Threshold Screening Tool to see if you are required to file a P2 Plan on myDEQ. If the result shows that you are required, you will be able to create a myDEQ account at that point and begin filing your new P2 Plan. If the result shows that you are not required to file a P2 Plan, you will be able to file voluntarily or if you do not want to create a voluntary P2 Plan, you will have a copy of your information for your records | Use Threshold Screening Tool >

Step 4

Maintain Your Plan

If your facility has filed a P2 Plan on myDEQ and it has been approved by staff, you must maintain your Plan. Each year by July 1, you must submit your Toxic Data Report (TDR), which consists of your Annual Progress Report (APR) and applicable TRI reporting. The APR is available on myDEQ as soon as January 1 each year | View/Download Guide > | Submit TDR in myDEQ >