In Washington, salts of epinephrine are also P042 if they are the sole active ingredient. We differ from the U.S. Environmental Protection Agency’s (EPA) interpretation that epinephrine salts are not P042 listed waste. We consider salts of epinephrine to be P042 since the sole active ingredient is still epinephrine.
The primary purpose of the salt is to make the epinephrine soluble. Salts of epinephrine include epinephrine hydrochloride and epinephrine bitartrate, but not norepinephrine. Note: We are delegated by EPA to enforce RCRA, the federal hazardous waste regulations. Delegated authorities must be at least as stringent as EPA’s regulations, and may be more stringent. Delegated states must make their own regulatory interpretations.
Our Dangerous Waste Regulations, Chapter 173-303 WAC are more stringent than RCRA because we have state-only criteria for toxicity and persistence (WAC 173-303-100).
Do not dispose of these pharmaceuticals in the sewer, sharps container, or a regulated medical waste container. Manage these as dangerous waste at a RCRA-permitted facility. It's the law.
Designating epinephrine waste
An unused or partially administered dose of injectable epinephrine is considered a discarded chemical product since it is not used for its intended purpose.
- A discarded formulation that has epinephrine or a salt of epinephrine as the sole active ingredient is a P042 listed waste.
- Residues of formulations with epinephrine or a salt of epinephrine are a P042 acutely hazardous waste. The container is also a P042 listed waste since it is not practical to triple-rinse pharmaceutical containers.
- Formulations where epinephrine is not the sole active ingredient are not RCRA listed waste. You must determine if it is a RCRA characteristic waste (WAC 173-303-090) for ignitability, corrosivity, or reactivity. For example, a syringe with epinephrine and lidocaine is not considered a P042 waste since there is more than one active ingredient. However, if the formulation’s pH is less than or equal to 2, it is a RCRA hazardous waste for corrosivity with a waste code of D002.
- If the epinephrine is not a listed waste and is not a RCRA characteristic waste, you can assume it is a state-only dangerous waste (WT02 down to 0.01%).
Containers that held epinephrine are considered P-listed waste since the residue inside is not used for its intended purpose. Containers can include syringes, IVs, vials, and ampoules.
- The container is dangerous waste unless it is triple-rinsed. You must manage the rinsate as P042 listed waste. It is not practical to triple-rinse pharmaceutical containers so they are usually managed as hazardous waste.
- Some containers, like syringes, can qualify as dual waste.
See Pharmaceutical Waste Designation Flowchart.
Note: We differ from EPA’s interpretation that the residue remaining inside a syringe has been used for its intended purpose. In Washington, the used epinephrine syringe is still a P042 listed waste.
Managing epinephrine waste
Epinephrine that is eligible for credit from a manufacturer, wholesaler, or reverse distributor is a viable pharmaceutical and not considered waste. Viable pharmaceuticals include any unused or unopened pharmaceutical that can be used or receive a credit. You must manage items not receiving a credit as waste.
RCRA hazardous epinephrine waste
- Non-viable formulations with epinephrine or epinephrine salts as the sole active ingredient (WAC 173-303-080).
- Containers that held formulations with epinephrine or epinephrine salts as the sole active ingredient.
- Formulations with a RCRA characteristic of ignitability, corrosivity, reactivity, or toxicity (WAC 173-303-090).
- Under the dangerous waste rules, accumulating more than 2.2 pounds (one liter) of any P-listed waste will make you a large quantity generator with additional requirements.
- Under the Interim Pharmaceutical Waste Policy, the listed waste will not count towards your generator category if it is sent to a RCRA-permitted incinerator as RCRA hazardous waste on a Uniform Hazardous Waste Manifest.
State-only dangerous waste
You can assume epinephrine formulations that are not RCRA hazardous waste are state-only dangerous waste. To determine the waste is not a state-only dangerous waste, you must know the concentration of epinephrine and all other ingredients and acute toxicity information of those ingredients.
- Manage as either dangerous waste at a RCRA-permitted facility or as excluded waste at an incinerator meeting the criteria of the Conditional Exclusion.
See Pharmaceutical Waste Management Flowchart.