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Pollution Prevention (P2) Program

Determining a Business’s Eligibility

Revised On: Jun. 15th, 2026 - 03:29 pm

The Pollution Prevention (P2) Planning Program assists certain businesses in reducing toxic substance use and hazardous waste generation at their source. The steps and resources below will help facilities determine whether they are subject to Arizona P2 planning requirements and guide them through the filing process.  

Step 1

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

Filing a P2 Plan is mandatory for facilities that exceed established  applicability thresholds for toxic substance use or hazardous waste generation.1 Businesses that do not meet the following thresholds may still choose to submit a plan voluntarily.

The applicable P2 thresholds under A.R.S. § 49-963 include:

  • The facility was required to submit an annual Toxic Chemical Release form (EPA Toxics Release Inventory (TRI) Form A or Form R) for the previous calendar year | Learn More >
  • The facility generated or shipped off-site 26,400 lbs or more of a non-acute hazardous waste, or 26.4 lbs or more of an acute hazardous waste, for purposes other than recycling, during the preceding calendar year.
  • The facility used more than 10,000 pounds of a toxic substance, as defined in A.R.S. § 49-9612, during the preceding calendar year. Refer to the EPA TRI for a comprehensive list of regulated chemicals and categories | View List >

If your facility meets any of the listed criteria, 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.

If your facility meets any of the following exemptions, a P2 Plan is not required. The department welcomes voluntary submission of a P2 Plan. 

A facility is exempt from Arizona P2 Program Reporting Requirements if the facility:

  • Is located on Tribal land.
  • Is a household hazardous waste collection facility.
  • Is primarily engaged in receiving waste from off-site and has a permit or plan approved under A.R.S. § 49 for storing, treating or disposing of solid, special, or hazardous waste. 
  • Is required to file solely due to the storage, supply, application or use of a pesticide as defined in A.R.S. § 3-361 for agricultural application and is subject to the pesticide reporting or record keeping requirements, pursuant to A.R.S. §49-305 or rules adopted pursuant to A.R.S. § 3-363.
  • The facility's industry is issued an agricultural general permit pursuant to A.R.S. § 49- 947.
  • All of the toxic substances used are for metallurgical or mining purposes (A.R.S. §49-963).
    Note: If the facility meets the hazardous waste filing thresholds defined in A.R.S. § 49-962(2) the facility will be required to submit a P2 Plan even if all the toxic substances are used in the metallurgical or mining operations. For clarification of mining and metallurgical operations and related activities, refer to the associated substantive policy: Pollution Prevention Plans (A.R.S.§ 49-963)  – Interpretation of “Mining and Metallurgical Operations” and “Used” — 4000.2026 | View >
  • Caused a one-time, unexpected, event that generates a hazardous waste or an acutely hazardous waste from an unused hazardous substance and; 
    • The unused hazardous substance cannot be lawfully used due to changes in statute, or rule and; 
    • A toxic data report has been filed for the event as prescribed in A.R.S. § 49-962 and; 
    • The toxic data report is required solely as a result of the one-time generation event. 

ADEQ Substantive Policy: Pollution Prevention Plans (A.R.S.§ 49-963) – Interpretation of “Mining and Metallurgical Operations” and “Used” — 4000.2026 | View Policy >

If your facility does not meet any of the filing exemption criteria, proceed to Step 3.

Step 3

Use the Threshold Screening Tool

Complete the Threshold Screening Tool in myDEQ as part of the P2 applicability determination process. Information entered into the tool will be used to initiate the filing process and establish facility records within myDEQ. The Threshold Screening Tool is free to use and does not require a myDEQ login | Use Threshold Screening Tool > | Visit the myDEQ Help Center >

Step 4

Maintain Your Plan

If your facility has filed a P2 Plan in myDEQ and it has been approved by staff, you must maintain your plan throughout its approved duration. Facilities should monitor the selected plan end date, at which point a plan amendment will be required.

Each year by July 1, facilities must submit a Toxic Data Report (TDR), which consists of your Annual Progress Report (APR) for the previous reporting year and applicable TRI reporting, if required. 

The APR becomes available in myDEQ beginning January 1 of each year | View New P2 Plan Guidance >

For all reporting resources, view the P2 Plan Assistance Guide | View P2 Plan Assistance Guide > 

1Arizona Revised Statutes (A.R.S.) § 49-963 | View 1 >

2A.R.S. § 49-961 | View 2 >

P2 Program Coordinator
Ph: 602-771-8083
Email >