A number of misconceptions have arisen around the proper methods for segregating and disposing of pharmaceutical waste. We’ve designed the following questions to assist you in coming to a better understanding of this important waste management challenge.

    No! One of the most common misconceptions is that hazardous chemical waste can be “red-bagged.” Red-bag waste is by definition biohazardous, infectious waste. Treatments such as autoclaving, microwaving, or even lower temperature incineration renders the infectious waste harmless but often has no impact on the hazardous chemical waste identified by EPA. Hazardous chemical waste must be properly stored, manifested, transported, and incinerated following specific regulations and using federally permitted transporters and incineration firms. “Cradle to grave” tracking insures that spills or releases anywhere en route are handled in an environmentally responsible manner. RCRA-permitted incineration facilities, known as TSDFs (Treatment, Storage, and Disposal Facilities) burn these chemicals at temperatures high enough to break down the chemicals into their individual components, such as carbon dioxide and water. All potentially toxic elements and compounds, such as heavy metals and carbon dioxide, released during combustion are removed from the stack so that only water vapor is released into the environment.

    Common pharmaceuticals such as nicotine, warfarin (Coumadin®), and a number of chemotherapeutic agents are federally regulated as hazardous waste and must be managed differently than other solid waste. A number of states have stricter definitions of hazardous chemical waste which includes pharmaceuticals. Our database now includes these precise waste categories for those states to make compliance easier.

    Based on EPA regulations (see 40 CFR 261.7 Residues of hazardous waste in empty containers.), a container that holds the chemotherapy agent arsenic trioxide, which is a P-listed hazardous waste, is not “RCRA empty” unless all the contents have been removed and it is triple rinsed. Since this is not feasible in a healthcare facility, all containers that have held arsenic trioxide should be discarded as hazardous waste, regardless of contents. The other six chemotherapy drugs regulated by EPA as hazardous waste are U-listed. If all the contents have been removed that can be removed through normal means (such as drawing liquid out with a syringe), and there is no more than 3% by weight remaining, the container is considered “RCRA empty” and can be disposed as trace chemotherapy waste in the yellow container. If either of these criteria is not met, it should be disposed of as hazardous waste and would be considered bulk chemotherapy waste. To bring your organization into compliance quickly, we provide the PharmE®Implementation Program, the PharmE® Inventory Analysis, the patented PharmE® Waste Wizard®, the PharmE® Computer-based Training Programs, and the PharmE® Policy and Procedure Templates.

    The PharmE® Waste Wizard® identifies which products become federal hazardous waste when discarded based on the EPA’s Resource Conservation and Recovery Act and recommends the appropriate waste stream. The Wizard also indicates which products become hazardous waste in those states that have stricter definitions. In addition, the Wizard identifies hazardous products, such as some chemotherapy agents, which are not regulated as hazardous waste federally but should be treated as hazardous waste based on their potential to cause harm. We refer to these as PharmE Hazardous® waste. The Wizard will also provide a link to your state’s regulations and significant interpretations.

    For each specific product, PharmEcology has developed multiple criteria based on the EPA regulations, such as toxicity, ignitability, corrosivity, and reactivity. The Wizard also indicates if a product meets the stricter definition of a state hazardous waste and provides the appropriate state waste code. Depending on which criteria are met for that item, a hazardous waste designation and recommended waste stream are given in the search results. For those items, such as some chemotherapy agents, which are recognized as hazardous drugs by the healthcare industry, NIOSH, and OSHA, but not by EPA, a PharmE Hazardous® waste category is indicated, suggesting a recommended hazardous waste stream. The PharmE® Waste Wizard® also provides a link to the state’s hazardous waste regulations and to relevant interpretations.