All Drug Waste Is Not the Same
Pharmaceutical waste management is a critical activity for health care facilities, yet it is often a challenge. Appreciating the different kinds of drug waste and their appropriate disposal methods is key to meeting regulatory, safety and environmental obligations.
In general, there are four categories of pharmaceutical waste of which to be aware.
Non-RCRA Waste
These types of pharmaceuticals fall outside of the Environmental Protection Agency’s (EPA’s) Resource Conservation and Recovery Act (RCRA) of 1976. Although non-RCRA drugs may not be considered hazardous waste, it is not recommended (and, depending on the location, may even be prohibited) to dispose of them with regular trash. It is recommended that non-RCRA drug waste be incinerated to prevent any negative environmental impacts. Other waste—including regulated medical waste—may not be destined for the incinerator, so non-RCRA drugs should be disposed of in separate containers that are marked for incineration.
RCRA Waste
Considered a hazardous waste, the EPA mandates that RCRA waste be disposed of in separately labeled containers. Black containers are the most commonly used, however there is no specific requirement about the color. The key is to choose a color and stick with it throughout your facilities, so workers can easily identify where these hazardous waste pharmaceuticals go.
P-listed waste is a type of RCRA waste, which is acutely hazardous. Organizations should have designated containers for P-listed waste that are properly labelled and documented. It is also important to have separate hazardous waste storage areas for P-listed waste, so you can track the amount you generate. The quantity must be weighed and documented every 30 days.
Another kind of RCRA waste is characteristic waste, which is waste that has one of several features or characteristics that makes it a hazardous waste: ignitability, corrosivity, reactivity or toxicity. In some cases, you may need to dispose of this waste in different containers from other RCRA waste. For example, asthma inhalers and other aerosols are potentially ignitable and must be thrown away in other receptacles for aerosols.
Chemotherapy Waste
Some chemotherapy drugs are a U-listed waste , which is a type of RCRA waste that is toxic to people and the environment. It can be found in trace and bulk amounts. When a U-listed or non-listed chemotherapy drug container is empty and less than 3 percent of the original weight remains, it is considered a trace amount. The container should be tossed in a yellow trace chemo waste receptacle and managed as a separate regulated medical waste labeled for incineration. If more than 3 percent remains, however, it is considered bulk waste and should be disposed of in black pharmaceutical waste containers. P-listed waste is never handled as trace chemo.
Controlled Substance Waste
This is any drug that falls under the Drug Enforcement Agency (DEA) definition of a controlled substance and can include morphine, hydrocodone and other opioids. Although there are no DEA specifications about the correct container for controlled substance disposal, it can be valuable to use one that houses adeactivating agent, which immediately renders the drug useless.
Keeping track of what waste goes where isn’t always easy. However, working with a pharmaceutical waste and controlled substance waste expert, such as Stericycle, can ensure you design a program that is safe and compliant.
