(Brookfield, WI – December 12, 2018) PharmEcology Services, WM Sustainability Services
Based on concerns expressed by industry regarding the inability of healthcare facilities to list the entire PHARMS code in Item 13 required under the new 266 Subpart P Hazardous Waste Pharmaceuticals which went into effect in non-authorized states August 21, 2019, EPA has issued an alternate code, PHRM, which fits into the paper hazardous waste manifest which is still in common usage. The PHARMS code does work in the e-Manifest system, but many generators are still using the prior manual system which is limited to four characters. It’s important to note that while specific hazardous waste codes are not required for facilities operating under subpart P, many authorized states have not yet adopted subpart P and specific hazardous waste codes are still required. Neither the PHARMS nor the PHRM code is sufficient when manifesting hazardous waste pharmaceuticals from those states. EPA also notes in the memo that if the shipment passes through states that have not yet adopted Subpart P or the receiving TSDF is in a state that has not yet adopted, hazardous waste codes may still be required and the generator should check with those states to determine their requirements. The memo may be accessed at https://rcrapublic.epa.gov/files/14919.pdf.