The following information was released by Janet Bowen of EPA Region 1. Please check the EPA website noted for the full document.
1. Scope of Hazardous Waste Listing PO42 (Epinephrine), October 15, 2007
The purpose of this memorandum is to clarify the scope of the hazardous waste listing for the commercial chemical product epinephrine (Hazardous Waste Code P042) under the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations. This clarification is in response to recent inquiries from some EPA regions, states and the regulated community specifically regarding whether this listing includes epinephrine salts. This is of particular significance because it is our understanding that most if not all of the chemical that is in use in hospitals (e.g., most medical applications) is one of several epinephrine salts. As described in the memo, we have determined that the scope of the P042 listing does not include epinephrine salts.
Please note that the memo also notes that the regulatory clarification presented in this memorandum applies to the federal hazardous waste program. As most state regulatory agencies are authorized to implement the hazardous waste program in lieu of the federal program, some states may regulate epinephrine salts more stringently than the federal regulations. Therefore we recommend that the regulated community contact their state regulatory agencies to ascertain the scope of the P042 listing in that state.
The entire memo is a very large file and may crash servers. You can retrieve it from EPA's site at US EPA Memo: Scope of Hazardous Waste Listing.
PharmEcology® Associates, LLC of Brookfield, WI was founded in 2000 and provides pharmaceutical waste management consulting services to the healthcare industry through seminars, on-site risk assessments, and other custom consulting services, in addition to the PharmE® Waste Wizard and PharmE® Inventory Analysis. Contact us at 262-814-2635 or email us at firstname.lastname@example.org.