Nicotine waste

Nicotine is on the discarded chemicals list. Healthcare facilities and hospitals can use the guidance below to manage nicotine waste at their facilities.

  • Do not dispose down the sewer.
  • Do not dispose in sharps containers.
  • Do not dispose in regulated medical waste containers destined for the landfill.

It is a violation of the dangerous waste rules to do so.

Types of nicotine products

  • Patches
  • Gum and lozenges
  • Inhalers
  • Sprays

How to designate nicotine waste

The active ingredients in a product determine how a product will designate:

  • Products where the sole active ingredient is nicotine or nicotine salt: When discarded or unused for its intended purpose, it becomes a P-listed waste with waste code P075.
  • Products with another active ingredient besides nicotine or nicotine salt: When discarded or unused for its intended purpose, will likely designate as state-only dangerous waste for toxicity.

Nicotine patches, gum, and lozenges

  • If opened and unused, the item and its wrapper are a P075-listed waste.
  • If it has been used for its intended purpose, it is no longer a P075-listed hazardous waste. However, it still may be considered state-only dangerous waste for toxicity.
  • The product wrapper would not carry the P075 assuming that the nicotine patch is being administered and therefore still a product when removed from the wrapper. No listing would apply. The packets (container/inner liner) would be a solid waste.

Nicotine inhalers and sprays

  • If opened and unused, the entire cartridge is a P075-listed waste.
  • If it has been used for its intended purpose, but there is still a residue of nicotine remaining inside the cartridge or bottle, it is still a P075-listed hazardous waste. It may also be dangerous waste for toxicity under our state-only criteria.

How to manage nicotine waste

Viable nicotine

Nicotine products 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 waste.

RCRA hazardous nicotine waste

Manage as a dangerous waste at a RCRA permitted facility. This includes:

  • Non-viable formulations of nicotine and nicotine salts that designate as listed wastes or under the RCRA characteristics of ignitability, corrosivity, reactivity, or toxicity.
  • Any discarded containers with nicotine residue that have not been triple-rinsed.

Under the dangerous waste regulations, accumulating more than 2.2 pounds of any P-listed waste, including nicotine, will make you a large quantity generator with additional requirements.

State-only dangerous waste nicotine

You can assume nicotine 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:

  • Remaining concentration of the nicotine and other ingredients.
  • Acute toxicity information of the nicotine and other 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.