Managing pharmaceutical patches
An increasing number of medications are available in patches. They must still be managed properly if they contain toxic chemicals. Some examples of these patches include:
- Scopolamine for motion sickness
- Nicotine replacement (NicoDerm CQ, Habitrol)
- Pain relief (Duragesic, Fentanyl, Lidoderm, Lidocane)
- Anti-inflammatory drugs
- Hormone replacement therapy
- Contraceptive medicines (estrogen and progesterone, norelgestromin/ethinyl estradiol)
- Blood pressure medication
It is a violation of the dangerous waste rules to dispose of patches in the sewer, sharps container, or a regulated medical waste container.
Unused patches should be returned to the pharmacy or a reverse distributor for credit whenever possible. If the patch is a non-viable pharmaceutical waste, you must determine if it is a Resource Conservation and Recovery Act hazardous waste or a state-only dangerous waste. Some unused patches (like nicotine) will be RCRA hazardous waste since it is a discarded chemical product containing a listed ingredient as a sole active ingredient.
Although a used patch’s pharmaceutical concentration may be below therapeutic doses, there is usually enough remaining on the patch to be considered a dangerous waste. Unless the used patch is properly designated, you can assume it is a RCRA hazardous waste. If you have determined the used patches are not RCRA hazardous, you can assume they are state-only dangerous waste eligible for management under the Conditional Exclusion.
Managing non-viable patches
RCRA hazardous waste patches
This includes unused patches with a P-listed or a U-listed sole active ingredient or any patch that fails the RCRA characteristics (see Profiling and Notification Factsheet).
Follow the US Drug Enforcement Administration’s (DEA) guidelines for transportation and witnessed destruction. Manage as a RCRA hazardous waste at a RCRA-permitted facility.
Not a controlled substance
Manage as a dangerous waste at a RCRA-permitted facility.
State-only dangerous waste patches
Assume any patches that are not RCRA hazardous waste are state-only dangerous waste. To determine a patch is not a state-only dangerous waste, you must know the remaining concentration of the pharmaceutical in the patch as well as the acute toxicity information of the pharmaceutical.
Follow the DEA guidelines for transportation and witnessed destruction. Manage as either a dangerous waste at a RCRA-permitted facility or as excluded waste at an incinerator meeting the criteria of the Conditional Exclusion.
Not a controlled substance
Manage as either a dangerous waste at a RCRA-permitted facility or as excluded waste at an incinerator meeting the criteria of the Conditional Exclusion.