Frequently asked questions about pharmaceutical waste

The special requirements for management of dangerous waste pharmaceuticals are based on U.S. Environmental Protection Agency’s (EPA) federal management standards for hazardous waste pharmaceuticals.

There are two significant differences between the EPA’s standards and ours:

• We include state-only dangerous waste pharmaceuticals in addition to federal hazardous waste pharmaceuticals.

• We require long-term care facilities to determine if the special requirements apply to them based on the amount of dangerous waste they generate.

No. The special requirements do not apply to:

• Nonpharmaceutical dangerous waste generated by the health care facility.
• Pharmaceuticals that are legitimately used, reused, donated, or reclaimed — including over-the-counter pharmaceuticals.
• Pharmaceutical waste from households.

If you follow the management and disposal requirements in the Interim Pharmaceutical Waste Policy, the amount of pharmaceutical waste will not count toward the total dangerous waste generated throughout your facility.

Your facility is an SQG if:

1. The amount of non-pharmaceutical dangerous waste is less than 2.2 pounds of either P-listed acutely hazardous waste or WT01 extremely hazardous waste per month; 
2. All other dangerous waste is less than 220 pounds per month; and 
3. You never accumulate more than 2200 pounds on site at any time.

You may then manage:

• Non-pharmaceutical waste as an SQG. 
• Pharmaceutical waste according to the policy.

You must show an inspector that:

1. Your facility creates less than 2.2 pounds of either P-listed acutely hazardous waste or WT01 extremely hazardous waste per month, and
2. Less than 220 pounds of all other dangerous waste per month.

Remember these rules as you count your dangerous waste:

• Keep records showing the generation locations and rates.
• Monthly generation rates apply throughout your facility.
• If the amount of dangerous waste generated nears the limit or fluctuates, consider managing your waste at a higher medium or large quantity generator category to ensure compliance in any given month.

Here are some examples:

1. Your lab generates 30 pounds of dangerous pharmaceutical waste per month. Elsewhere on site you generate 200 pounds of dangerous waste per month. You must count these wastes together as 230 pounds per month. In this case you are an MQG, not an SQG, and must follow MQG requirements.
2. The total dangerous waste from your facility is 150 pounds per month but that includes 3 pounds of epinephrine P-listed waste. You have exceeded the 2.2 pound Quantity Exclusion Limit (QEL) for P-listed waste and are an LQG and must follow LQG requirements.
3. Your facility generates no more than 200 pounds of dangerous waste per month and you have no P-listed or WT01 wastes. But, you have accumulated more than 2200 pounds of dangerous waste on site to minimize disposal costs. In this case you are an LQG and must follow LQG requirements.

To learn more:

• Refer to the Dangerous Waste Regulations, Chapter 173-303 WAC.
• The Guide for Dangerous Waste Generators in Washington State has information about generator category, requirements, and it compares compliance conditions between the dangerous waste regulations and the interim policy.
• Call the Hazardous Waste and Toxics Reduction Program at your regional Ecology office for help.

Keep collected household pharmaceuticals separate from your business waste:

• Returned household-exempt pharmaceutical waste collected in a separate container can be managed as moderate risk waste under WAC 173-350-360
• Business waste cannot be included with household-exempt pharmaceutical waste
• Provide clear procedures to staff
• Provide clear labeling

Hospital pharmacies who offer a separate medicine return collection program can be classified as a Product Take-Back Center under the definition of WAC 173-350-100, and are exempt from solid waste permitting if the waste is managed under specific criteria.