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Microsoft word - pharmwasteguidance_26_march_2009_draft _2_
Pharmaceutical Waste Guidance
1. Hazardous Waste Determinations
The Florida Department of Environmental Protection (FDEP) has recently received a number of requests
for help in determining whether hospital wastes are regulated as hazardous wastes under the federal
Resource Conservation and Recovery Act (RCRA) and corresponding state law. Therefore, we are
issuing the following regulatory determinations with regard to medications formulated from chemicals
that the Environmental Protection Agency (EPA) has listed as hazardous under 40 Code of Federal
Regulations (CFR) 261.33 or that include ingredients that may cause the medication to exhibit the
toxicity characteristic under 40 CFR 261.24. [All sections of 40 CFR mentioned in this guidance have
been adopted by reference as Florida law in Chapter 62-730, Florida Administrative Code (FAC).]
Pharmaceutical waste that meets the definition of hazardous waste may be managed as “universal waste”
in Florida. This is a somewhat less stringent set of requirements which may be found in Rule 62-
730.186, FAC. This guidance document is current as of 26 March, 2009
EPA published a regulatory interpretation memo October 15, 2007 concluding that the listing
description for epinephrine does not include salts. Epinephrine HCL and epinephrine bitarterate, the
medically active forms of epinephrine in common use, are salts. Therefore, expired or damaged
medications, including used syringes such as Epi-Pens, that contain epinephrine or epinephrine
residues as the sole active ingredient no longer have to be managed as hazardous waste (or universal
waste in Florida) when discarded. This includes lidocaine preparations containing epinephrine.
Nicotine is listed as an acutely hazardous waste in 40 CFR 261.33. FDEP agrees that used nicotine
patches and gum are not hazardous waste because the listing description applies only to unused
commercial chemical products and spill residues. Unused nicotine patches and gum are hazardous
FDEP has adopted EPA's revisions to Part 261 that exempts waste nitroglycerine formulations that
are not explosive from regulation as hazardous waste.
4. Warfarin/Coumadin - EPA Waste Nos. P001/U248 (if less than 0.3%)
In general, when unused and discarded, warfarin is P001, an acute listed hazardous waste. However, where the amount of warfarin in the waste is “present at concentrations of 0.3% or less,” the hazardous waste listing is U248. FDEP has laboratory data indicating that the amount of residue remaining in some containers which formerly held Coumadin (warfarin) pills ranges from 0.0033 to 0.0039%, compared with the initial amount of warfarin in the container. By extrapolation, the results
are applicable to bottles that formerly contained at least 50 coated tablets or capsules of Coumadin at a dosage of 10 milligram (mg), and bottles that formerly contained at least 110 coated tablets or capsules at a dosage of 1 mg. Therefore, FDEP has determined that containers which formerly held these two combinations of amounts and dosages are identified as U248 rather than P001. In that case, the containers would be “RCRA-empty” if all Coumadin pills have been removed. Triple rinsing is not required. “RCRA-empty” containers are not regulated as hazardous waste.
A generator of containers that formerly contained any other dosage/quantity combination of Coumadin pills, or that formerly contained liquid formulations or powders, may design and implement a laboratory study to demonstrate that the residues are <0.3% of the initial amount of warfarin in the container. Until such demonstration is made, containers that held other dosage/quantity combinations, or that held liquid or powder formulations, must be disposed of as P001 hazardous waste or triple rinsed in accordance with 40 CFR 261.7 to render them “RCRA-empty” and no longer hazardous waste.
EPA has been asked to review its national guidance on this matter, so FDEP’s interpretation is subject to revision based on the results of EPA’s evaluation.
Some over the counter medications such as Chloraseptic have phenol as the sole active ingredient.
These are listed hazardous waste when unused packages are discarded in the trash rather than used.
Phenol is the sole active ingredient, but is diluted with a carrier. Carriers, buffers, preservatives and
fragrances or flavors in these products are not included for a functional property, and may be present
in preparations without affecting their hazardous waste listing.
6. Hexachlorophene - EPA Waste No. U132
FDEP does not consider commercial cleaning preparations containing hexachlorophene such as
pHisoderm or pHisoHex to meet the listing description for technical grade Hexachlorophene.
Hexachlorophene is the main active ingredient, but is formulated with detergents and emulsifiers
which are included for their functional cleaning properties, so hexachlorophene is not the sole active
7. Chromium or Selenium supplements - EPA Waste Nos. D007 and D010
Waste liquids that have more than 5 milligrams per liter (mg/l) chromium or 1 mg/l selenium are
hazardous wastes because they exhibit the toxicity characteristic under 40 CFR 261.24. Solids that
contain these metals are also regulated if they leach these concentrations when tested by the toxicity
characteristic leaching procedure (TCLP) specified in this rule. For soluble metals, 100 mg/kg
chromium and 20 mg/kg selenium will fail the test. For vials and tablets of unused materials, most
will fail the TCLP test based on dose per weight of tablet or unit. Health care facilities must monitor
the concentration of the metals in diluted medications in order to determine if these are regulated as
hazardous (or universal) waste when discarded.
8. Chromic Catgut Sutures - EPA Waste No. D007
Unused, discarded sutures should be presumed to be hazardous waste. FDEP is authorizing disposal
of remnants and clippings generated during surgery as biomedical waste.
9. Insulin - potentially EPA Waste No. D024
Some insulin formulations contain m-cresol, and these are toxic hazardous wastes when m-cresol
levels exceed 200 mg/l TCLP. It is permissible under hazardous waste regulations to crush the vials,
handle the drained liquid as hazardous waste and manage the crushed glass as non-regulated material.
2. Best Management Practices for Medical Facilities
Generating Acutely Hazardous Waste
Certain essential drugs used in medical practices are regulated under RCRA as acutely hazardous waste,
or “P-listed” waste in 40 CFR 261.33. To be in compliance, the facility must dispose of unused
preparations of these as hazardous waste or as “universal waste.” Residues from a spill of unused
preparations of P-listed waste must be managed as hazardous waste. A list of P-listed chemicals/drugs
that may be on site can be found at the end of this BMP.
Following these simple guidelines will help your facility comply with RCRA.
1. Store all P-listed waste in a separate labeled container. It cannot be placed in the biohazard red
box. Items for the separate container labeled “hazardous waste” or “acutely hazardous waste”
include, but are not limited to, empty vials, bottles, and containers that contain or have contained
epinephrine. Unused intravenous solutions or medications that contain a P-listed compound also
must be disposed of as hazardous or universal waste. Only empty syringes used to administer the
2. The container must be picked up and disposed of EITHER by a hazardous waste transporter that
has registered with FDEP and has established financial assurance, OR by a transporter who has
notified FDEP of its universal waste transporting activities.
3. The hazardous waste transporter will give you a copy of the manifest. You must keep it on file
4. Assuming that no other hazardous wastes are generated, a facility that generates less than 2.2
pounds (1 kilogram) of acutely hazardous waste in any calendar month is categorized as a
Conditionally Exempt Small Quantity Generator (CESQG). Once this maximum amount is
exceeded the facility would be considered a Large Quantity Generator and subjected to stricter
regulations. The CESQG limit for non-acutely hazardous waste is 220 pounds (100 kilograms),
which is approximately one-half of a 55 gallon drum.
5. Keep in mind once a product has expired it is considered a waste under RCRA (unless it can be
returned to the manufacturer for credit), and must be disposed of in accordance with hazardous
waste regulations. You can keep disposal costs down by monitoring the inventory and only
keeping as much drug/chemical on site as needed.
3. RCRA “Listed Hazardous Waste” That May Be Found in Medical Practices
P-Listed hazardous wastes (acutely hazardous):
Not all the above chemicals/drugs are used in all practices
This is not a complete list of all chemicals/drugs that may become hazardous waste
For more information on hazardous pharmaceutical waste and universal pharmaceutical waste, please go
to FDEP’s website and click on “Pharmacies” and “Pharmaceuticals Potentially Hazardous Waste When
Discarded” under “General Hazardous Waste Publications” at
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