Managing pharmaceutical waste

Health care facilities include:

• Hospitals
• Clinics
• Doctor’s offices
• Dental clinics
• Veterinary clinics
• Pharmacies
• Long-term care facilities
• Ambulance services
• Outpatient surgery centers
• Medical clinics within larger facilities

What are noncreditable dangerous waste pharmaceuticals?

• Prescription dangerous waste pharmaceuticals that do not have a reasonable expectation to be eligible for manufacturer credit.
• Nonprescription dangerous waste pharmaceuticals that do not have a reasonable expectation to be legitimately used, reused, or reclaimed.

Examples include:

• Drugs pertaining to an investigation
• Free samples of pharmaceuticals
• Unusable pharmaceuticals in containers, like broken pills or partial liquid doses
• Pharmaceutical-contaminated personal protection equipment
• Floor sweepings
• Clean-up materials from spills of pharmaceuticals

How to manage noncreditable dangerous waste pharmaceuticals

• No sewering: Follow the sewer prohibition for dangerous waste pharmaceuticals.
• Notify Ecology: Use the Dangerous Waste Site Identification Form to notify us within 60 days that you are subject to the special requirements.
• Annual reporting: Exclude dangerous waste pharmaceuticals managed under the special requirements on your dangerous waste annual report (due by March 1).
• Training: Your facility must train personnel managing noncreditable dangerous waste pharmaceuticals.
• Empty containers: Determine when your pharmaceutical containers are empty.  
• Dangerous waste containers: Noncreditable dangerous waste pharmaceuticals must be:
  • Secured to prevent unauthorized access.
  • Stored in containers that are:
    • Closed when not in use.
    • Structurally sound and non-leaking.
    • Compatible with the contents.
    • Labeled or marked “Hazardous Waste Pharmaceuticals” or “Dangerous Waste Pharmaceuticals.”
    • Labeled or marked with the date the contents first became waste. Records can also be used to document waste has been on site less than one year.
• Shipping: Your facility may accumulate noncreditable dangerous waste pharmaceuticals on site for one year or less. After this time, it must go to a permitted treatment, storage, or disposal facility following the specific packaging requirements noted in the special requirements:
  • Use a Uniform Hazardous Waste Manifest to document shipments of noncreditable dangerous waste pharmaceuticals.
  • The letters “PHRM” can go on the manifest instead of waste codes.
  • DO NOT send noncreditable dangerous waste pharmaceuticals to a reverse distributor.
• Recordkeeping: Follow the same requirements as other dangerous waste.

What is a potentially creditable dangerous waste pharmaceutical?

A prescription dangerous waste pharmaceutical that has a reasonable expectation to receive manufacturer credit and is in original manufacturer packaging, undispensed, and unexpired or less than one year past expiration date.

This term does not include evaluated dangerous waste pharmaceuticals or nonprescription pharmaceuticals including, but not limited to, over-the-counter drugs, homeopathic drugs, and dietary supplements.

Using reverse distributors for potentially creditable dangerous waste pharmaceuticals

Any health care facility may send potentially creditable dangerous waste pharmaceuticals to reverse distributors provided you have a reasonable expectation of credit. 

• Do not send noncreditable dangerous waste pharmaceuticals to a reverse distributor.

It is your responsibility to verify that your reverse distributor:

• Has an active EPA/State ID Number
  AND
• Is regulated under one of the following:
  • WAC 173-303-555
  • RCRA subpart P
  • Equivalent out-of-state dangerous waste pharmaceuticals regulations

Receipt confirmation

Reverse distributors must confirm receipt of delivery of the potentially creditable dangerous waste pharmaceuticals shipment. If you do not receive confirmation within 35 calendar days, you must contact the carrier and the receiving facility to determine the status.

Recordkeeping

If your facility uses a reverse distributor for potentially creditable dangerous waste pharmaceuticals, you must keep paper or electronic records for each shipment for at least five years from the date of shipment. 

The records must:

• Confirm delivery.
• Be prepared according to USDOT regulation 49 C.F.R. Part 172, when applicable.
• Be readily available upon request by a compliance inspector.