Pharmaceutical waste containing mercury

Most wastes containing mercury are dangerous waste. Find guidance on managing mercury-containing pharmaceutical waste.

Designating pharmaceutical wastes that contain mercury

It is difficult to determine whether a drug contains mercury. Usually medical personnel do not have adequate information to designate mercury-containing pharmaceuticals without testing. We recommend you require your vendors to identify all mercury-containing products and provide mercury-free formulations when available.

RCRA hazardous waste

Mercury-containing pharmaceuticals can designate as: 

  • D009 toxic characteristic under the federal Resource Conservation and Recovery Act (RCRA); or
  • D009 state-only toxic criteria waste.

This includes non-viable formulations that designate under the RCRA characteristic of toxicity (D009) when the concentration of mercury is greater than 0.2 ppm. An example of a RCRA hazardous waste is thimerosal (D009).

State-only dangerous waste

You can assume non-viable formulations that are state-only dangerous waste if they are not a RCRA hazardous waste. To determine if the waste is a state-only dangerous waste, you must know the:

  • Concentration of the mercury constituent. 
  • Acute toxicity information.

For more information:

Managing waste mixtures

Viable formulations

Unused pharmaceuticals that are eligible for credit from a manufacturer, wholesaler, or reverse distributor are viable pharmaceuticals and not considered waste. Viable pharmaceuticals include:

  • Unused pharmaceuticals that receive a credit.
  • Unopened pharmaceuticals that receive a credit.

Items not receiving a credit must be managed as non-viable waste.

RCRA hazardous waste

Dispose as a hazardous waste at a RCRA-permitted facility.

State-only dangerous waste

Dispose at a:

See the Pharmaceutical Waste Designation Flowchart

Can mercury waste go down the drain?

  • Don't dispose of mercury wastes down the drain.
  • Don't dispose of mercury into soiled linens destined for the laundry.
  • Get authorization from your local sewer authority to dispose of any process waste to a sanitary sewer.

Sewer agencies may NOT accept dangerous wastes. The sewer authority will also consider how the compounds will affect their treatment system and the microorganisms.

Mercury in the environment

Mercury-containing products, regardless of their designation, can lead to contamination when thrown in the trash, where they might be crushed or incinerated. Mercury can evaporate into the air where it can then enter the water and soil.

Fish accumulate mercury in their bodies. This in turn can expose people and wildlife to mercury through consumption of fish. Children and fetuses are the most vulnerable to the effects of mercury. Exposure can affect learning and behavior later in life.