After you have designated your waste, determine whether your dangerous waste pharmaceuticals fall under the 2.2 lb QEL or the 220 lb QEL.
What is a QEL?
Quantity exclusion limit (QEL) is a monthly weight limit based on the type of waste you are counting:
- Most dangerous wastes have a QEL of 220 pounds.
- Dangerous wastes that are extremely toxic in small amounts have a QEL of 2.2 pounds. This includes:
How to find the weight of your dangerous waste pharmaceuticals
It is difficult to find the actual weight of dangerous waste pharmaceuticals.
You can choose one of the following options:
- Do twice monthly weigh-ins and count the difference:
- Weigh a waste container at the beginning of the month. Record the weight (A).
- Weigh the container at the end of the month. Record the weight (B).
- Subtract A from B.
- This is the weight of the dangerous waste pharmaceuticals you generated over one month.
NOTE: This will result in an overcount since the individual packaging weights are included.
- Keep a log of each waste amount generated. This method results in a more accurate count since the packaging weight is not counted, but is more time intensive for staff to log:
- Track the individual volume or weight of dangerous waste pharmaceuticals every time you add to your waste container.
For example: If only half of a 1 mL prefilled syringe of epinephrine is administered, track 0.5 mL on your log when the whole syringe is added to your waste container.
- Total these individual amounts at the end of the month.
- This is your dangerous waste pharmaceutical count (in pounds) for the month. If you are tracking by volume, convert to pounds.
Yes. Health care facilities must count all dangerous waste. This includes potentially creditable dangerous waste pharmaceuticals.
Potentially creditable dangerous waste pharmaceuticals are waste even if you receive a manufacturer credit.
Yes. Health care facilities must count all dangerous waste each calendar month to determine if the special requirements apply.
This includes:
- Dangerous waste pharmaceuticals, such as:
- Any non-empty pharmaceutical containers.
- Partial doses.
- Dropped pills.
- Expired medications.
- Potentially creditable dangerous waste pharmaceuticals sent to a reverse distributor.
- Nonpharmaceutical dangerous waste, such as:
- Cleaning supplies.
- Disinfectants.
- Lab chemicals.
- X-ray fixer.
- Paint.
- Solvents, including accumulated solvents prior to distilling.
No, you cannot take a waste shipment weight and divide by the number of months to determine the count.
- You must count your dangerous waste each month.
- You cannot average multiple months over time.