Waste vitamin and mineral preparations

Waste vitamin and mineral preparations may designate as a dangerous waste. However, these preparations do not qualify for either the Conditional Exclusion or the Interim Pharmaceutical Waste Policy. This is because they do not meet the definition of a “drug,” see RCW 69.41.010. These preparations are subject to all applicable requirements of the Dangerous Waste Regulations, Chapter 173-303 WAC. Find guidance here on managing these preparations.

Return unused, unopened, and undiluted vitamin and mineral products as products to a reverse distributor or manufacturer if credit is available. If reverse distributors or manufacturers cannot provide credit for unused vitamin and mineral products, they become waste and cannot be returned.

Expired products and unused preparations are waste. Both diluted and undiluted forms may have constituents that cause them to designate as dangerous waste.

Designation of vitamin and mineral preparation wastes

Resource Conservation and Recovery Act (RCRA) hazardous waste includes waste that has the federal RCRA characteristics of ignitability, corrosivity, reactivity, or toxicity, WAC 173-303-090. The most common concern is the concentration of RCRA toxicity characteristic metals, including arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. For example, oil-soluble prenatal formulations and some homeopathic remedies contain mercury or mercury compounds.

State-only dangerous waste: If the wastes do not designate as RCRA hazardous waste, they must be evaluated to determine if they are state-only dangerous waste. To determine that a waste is not state-only dangerous waste, you must know the concentration of all constituents in the waste and their toxicity. Refer to WAC 173-303-100.

Follow our step-by-step guide to designating waste.

Management of vitamin and mineral preparation wastes

If the waste designates as RCRA hazardous waste or state-only dangerous waste, they must be stored, labeled, accumulated, and disposed of according to the applicable requirements of the dangerous waste regulations. The publication Guide for Dangerous Waste Generators in Washington summarizes these requirements based on your facility’s generator category.

When waste vitamin and mineral preparations designate as dangerous waste, they do not qualify for either the Conditional Exclusion or the Interim Pharmaceutical Waste Policy. Facilities that are a medium or large generator of dangerous wastes must dispose at a RCRA-permitted incinerator. Small quantity generators dispose of their dangerous wastes by shipping off site to a permitted treatment, storage, and disposal facility, or to a permitted moderate risk waste or solid waste facility.

Note: it is a violation of the dangerous waste rules to dispose of these pharmaceuticals in the sewer, in a sharps container, or in a regulated medical waste container destined for a landfill.