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Pharmaceutical waste definitions

Some of these terms are defined from the dangerous waste regulations and others were written to provide clarity for pharmaceutical waste managed under the Interim Pharmaceutical Waste Policy.

Commercial chemical product - Pharmaceuticals are commercial chemical products. A substance manufactured or formulated for commercial or manufacturing use consisting of:

  • The commercially pure grade of the chemical;
  • Any technical grades of the chemical; or 
  • Any formulations in which the chemical is the sole active ingredient.

Conditional exclusion - Only pharmaceuticals that designate as state-only dangerous waste are eligible for management under the Conditional Exclusion.

If managed correctly under the exclusion, your state-only pharmaceutical waste:

  • Does not need to be counted toward your generator status, and
  • Does not need to be reported annually.
The conditional exclusion requires the incineration of state-only pharmaceutical waste at either:
  • A facility permitted to incinerate municipal solid waste; or
  • A controlled combustion unit with heat input greater than 250 million British Thermal Units per hour (BTUs/hr), and combustion zone temperatures greater than 1500°F.

Dangerous waste - Any waste that designates under WAC 173-303-070(3). Dangerous waste includes:

Dual waste - Dangerous waste pharmaceuticals that are infectious or potentially infectious. An example of dual waste is a non-empty syringe containing a dangerous waste pharmaceutical with needle attached.

P-listed hazardous waste - Any commercial chemical product in which the listed chemical is the sole active ingredient.

Non-viable pharmaceutical - A pharmaceutical that cannot be used for its intended purpose, sold, or returned to the manufacturer, wholesaler, or reverse distributor for credit. This may include, but is not limited to:

  • Expired pharmaceuticals
  • Outdated items repackaged at the pharmacy
  • Dropped pills
  • Partial IVs, ampoules, ointments, creams, lotions, and inhalers
  • Patient medications left at the hospital
  • Samples

RCRA hazardous waste - For the purpose of pharmaceutical waste, RCRA hazardous waste is any pharmaceutical that designates as dangerous waste. RCRA hazardous waste includes:

  • Lists of certain discarded chemical products.
  • Manufacturing and industrial processes.
  • Wastes with hazardous characteristics of ignitability, corrosivity, reactivity, or toxicity.

Reverse distribution - The practice of shipping unwanted, viable pharmaceutical products to a third party with the intent of receiving manufacturer credit.

State-only dangerous waste - For the purpose of the Interim Pharmaceutical Waste Policy, state-only dangerous waste is any pharmaceutical waste that designates as dangerous waste but is not a RCRA hazardous waste. Washington considers toxicity and persistence as the criteria used to designate waste as dangerous in addition to the RCRA listing and characteristics.

Viable pharmaceutical - A pharmaceutical that can be used for its intended purpose or returned to a manufacturer, wholesaler, or reverse distributor for credit is viable. Viable pharmaceuticals are not subject to the dangerous waste regulations since they are considered product-like. Any pharmaceutical disposed without credit is non-viable unless there is a documented change in credit status by the reverse distributor.