Hazardous Drug Disposal Serviceresearch.tu.edu/biosafety/PharmacueticalWasteManagementWhiteP… · hospital’s formulary can be classified as hazardous waste. To identify which of

P R O T E C T I N G P E O P L E . R E D U C I N G R I S K . TM Waste2Green4Healthcare®

Sharps Management Service

Hazardous Drug Disposal Service

WHITE PAPER

Pharmaceutical Waste Management

http://www.stericycle.com/doctor-office-drug-disposal

TABLE OF CONTENTS

Hazardous Waste in Healthcare – A Regulatory Reality . . . . . . . . . . 1

Hazardous Waste Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Characteristic Hazardous Waste . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4

Listed (Commercial Chemical) Hazardous Waste . . . . . . . . . . . . . . 4-5

Waste Generator Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Hazardous Waste Accumulation . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7

Hazardous Waste – Containers, Manifests & Transport . . . . . . . . . 6-7

State Specific Classifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Consequences of Noncompliance . . . . . . . . . . . . . . . . . . . . . . . . . . 9

WHICH PHARMACEUTICALS ARE HAZARDOUS WASTE?About 5% to 10% of the pharmaceutical products in a hospital’s formulary can be classified as hazardous waste. To identify which of your pharmaceutical products are hazardous, you must understand how the EPA classifies hazardous waste because the hazardous waste classification process is no different for you than it is for a factory or chemical manufacturer . Surprising? But just as you would not expect the service provider that changes your car oil or antifreeze to toss it down the drain, the EPA does not condone disposing of hazardous pharmaceuticals via the water system .

There are four questions that must be answered to determine if a pharmaceutical product is regulated by the EPA as a hazardous waste:

1) Is it a solid waste?

2) Does it qualify for an exemption?

3) Is it a characteristic waste?

4) Is it a listed waste?

RX WASTE MANAGEMENT

The Issues and Regulation of Pharmaceutical Waste Management – overview The EPA’s recent focus on pharmaceutical waste management has been influenced by increasing

evidence of pharmaceuticals in drinking water. An Associated Press series on pharmaceutical waste

in May 2009, reported that EPA has found traces of pharmaceuticals in the drinking water of over 41 million

Americans . There is cause for concern regarding the unknown human and ecological impacts of trace amounts

of pharmaceuticals in the water we drink and the water that is crucial habitat for our flora and fauna .

The regulation of pharmaceutical waste is nothing new. Under the Resource Conservation and Recovery

Act of 1976 (RCRA), many pharmaceuticals have been classified as hazardous waste for more than thirty years .

This section paper report reviews the current pharmaceutical waste management requirements under RCRA and

provides guidance for the classification and management of pharmaceuticals that must be managed as hazardous

waste in accordance with the Federal EPA’s regulations . This paper does not address state regulatory requirements

nor requirements under other statutes that impact the pharmaceuticals, such as the Clean Water Act, Food Drug

and Cosmetic Act, Controlled Substances Act, etc .

Stericycle, Inc. Rx WASTE WHITE PAPER 1 www.stericycle.com


PHARMACEUTICALS AS HAZARDOUS WASTE?1) Is it a solid waste?All wastes must be evaluated to determine if they are solid wastes . If they are solid wastes, they must be immediately evaluated to determine if they are hazardous waste . However, you will find that many of the solid wastes that you generate are not regulated as hazardous waste .

The term “solid waste” has little to do with whether or not the material is a solid . Although the term solid waste is the term of art used in the regulations, the focus of this question is an assessment of how the material is currently or will ultimately be managed . A solid waste is defined as any discarded material that is either abandoned, recycled, or is inherently waste-like. In hospital settings, the abandoned portion of the definition is most relevant. A waste is abandoned when it is either disposed of, incinerated, or when it is accumulated before its being disposed of, or incinerated. Therefore, when you first accumulate a waste for its eventual disposal (such as drop a pill into a waste container), you have abandoned it and it is a solid waste.

How does this apply to shelf-life expired pharmaceuticals? In most cases, the expiration date is the date the product is abandoned and therefore it’s the date the material becomes a solid waste . Of course, a pharmaceutical product could become a solid waste before its expiration date, if it is accumulated for disposal before it expires .

Universal waste is a category of hazardous waste that has somewhat streamlined requirements established by the EPA . Currently, universal wastes include batteries, lamps, pesticides, and mercury containing equipment . The EPA has proposed to add pharmaceuticals to the list and two states, Florida and Michigan, have already done so . What does this mean to you?

When the EPA does eventually list pharmaceuticals as universal waste, they will still be required to be disposed of at facilities authorized by the EPA or your state environmental agency . Moreover, they will remain subject to DOT hazardous materials transportation regulations . That those pharmaceuticals that are subject to DOT requirements will have to be packaged, marked, labeled, placarded, and identified on DOT shipping papers .

The streamlined benefits of the universal waste rule apply primarily in how they are stored on-site and counted toward your generator status . Universal waste need not be stored in a satellite accumulation point or a 90-day storage area . Instead, universal waste can be stored in any safe location for up to one year on-site . Containers used to store universal waste must be structurally sound, kept closed and managed in a way that prevents releases to the environment . Universal wastes do not count toward your large/small quantity generator status; however, if you ever store over 5,000 kg of universal waste on-site, you will be classified as a large quantity universal waste handler and you will be required to notify your state of this status .

There are several options on how universal waste containers must be marked, including either the words “Universal waste” or “Waste” or “Used” followed by the name of the waste, such as lamps, batteries, mercury-containing equipment, pesticides, or pharmaceuticals .



2) Does it qualify for an exemption?There are several dozen exemptions that have been established either to encourage recycling or to avoid regulating wastes with low risks . Pharmaceuticals are rarely recycled and they do not qualify for most of the exclusions, which apply to very specific waste types .

3) Is it a characteristic waste?If a solid waste displays any of the following properties, known as characteristics, the waste must be managed as a hazardous waste: ignitable, corrosive, reactive, or toxic. These characteristics have very precise definitions, which are briefly summarized below . This summary does not take into account every exception or exclusion, therefore, we encourage you to review the full text of the regulations at 40 CFR 261 for additional details .

Ignitable (D001):

If a solid waste displays any of the following properties, it is an ignitable hazardous waste and is assigned the waste code D001:

• It is a liquid with a flash point less than 140° F . However, if an alcohol is the only constituent of the product that contributes to its ignitability, and if it is an aqueous alcohol solution containing less than 24% alcohol by volume, it is not ignitable . Bear in mind that a waste with more than 24% alcohol cannot be diluted to this concentration to reclassify it as non-hazardous without a hazardous waste treatment permit or similar authorization .

• It is a non-liquid that causes fire through friction, absorption of moisture, or spontaneous chemical change .

• It is a flammable gas or an oxidizer .

Examples of ignitable wastes include alcohol-based cough syrups, ethylene oxide, methanol, bromine tablets, zinc powder, xylene, aerosol cans with flammable propellants, and petroleum naphtha .

Corrosive (D002):

Strong acids, bases, and materials that are corrosive to steel are classified as corrosive, with the waste code D002 . This definition includes aqueous wastes with a pH of < 2 or > 12 .5 as well as liquids that can corrode steel at a rate greater than ¼ inch per year . Examples include glutaraldehyde, formic acid, hydrochloric acid, and sodium hydroxide solution .

Reactive (D003):

If a waste displays any of the following properties, it is classified as reactive hazardous waste . Unlike the other characteristics, there are no EPA-defined testing procedures, therefore you should refer to the product insert, MSDS, or other available data to determine if it could display any of these properties:

• It is normally unstable and readily undergoes violent change without detonating .

• It reacts violently with water .

• It forms potentially explosive mixtures with water .

• When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to health or the environment .

• It is a cyanide or sulfide-bearing waste which, when exposed to pH conditions between 2 and 12 .5, can generate toxic gases, vapors, or fumes that pose a danger to health or the environment .

• It is readily capable of detonation, explosive decomposition, or reaction at standard temperature or pressure .

• It is an explosive that is classified by the Department of Transportation (DOT) as being forbidden in transportation or it is classified as DOT divisions 1 .1 through 1 .3 .

Examples of reactive wastes include acetyl chloride, chromic acid, organic peroxides, hypochlorites, perchlorates, permanganates, sulfides, and non-empty aerosol cans containing flammable gases .



Toxic (D004 – D043):

Although there might be hundreds of thousands of products that could be toxic, the EPA only designates 39 chemicals (see Table 2), which if present in a waste, render the waste toxic . To determine the concentration of these chemicals, a test known as the Toxicity Characteristic Leaching Procedure (TCLP) is used.

Some of the chemicals to look for include selenium, silver, chromium, mercury, and cresol . Mercury and m-cresol are commonly used as vaccine preservatives .

4) Is it a Listed Waste?There are four lists of hazardous waste, known as the F-list, K-list, P-list, and U-list . Each of these lists is summarized below together with examples that could be found in hospital settings .

F-list

These are called non-specific source wastes because they could potentially be generated by a variety of facilities . Only the first few are found in hospital settings, but rarely in the pharmacy . These include spent solvents and degreasers containing, to name just a few, acetone, toluene, benzene, methyl ethyl ketone, and several others . An important distinction regarding the solvents on the F-list is that they only become hazardous waste after they

become spent following use as a solvent . If they are not used for their solvent properties, they are not F-list wastes, but could of course display one of the characteristics noted above . The complete F-list can be found at 40 CFR 261 .31 and is summarized in (see Table 1) .

EPA HW # Contaminant Regulatory Level (mg/l) EPA HW # Contaminant Regulatory Level (mg/l) D004 Arsenic 5 .0 D032 Hexachlorobenzene 0 .13

D005 Barium 100 .0 D033 Hexachlorobutadiene 0 .5

D018 Benzene 0 .5 D034 Hexachloroethane 3 .0

D006 Cadmium 1 .0 D008 Lead 5 .0

D019 Carbon Tetrachloride 0 .5 D013 Lindane 0 .4

D020 Chlordane 0 .03 D009 Mercury 0 .2

D021 Chlorobenzene 100 .0 D014 Methoxychlor 0 .10

D022 Chloroform 6 .0 D035 Methyl Ethyl Ketone 200 .0

D007 Chromium 5 .0 D036 Nitobenzene 2 .0

D023 o-Cresol 200 .0 D037 Pentachlorophenol 100 .0

D024 m-Cresol 200 .0 D038 Pyridine 5 .0

D025 n-Cresol 200 .0 D010 Selenium 1 .0

D026 Cresol 200 .0 D011 Silver 5 .0

D016 2,4-D 10 .0 D039 Tetrachlorethylene 0 .7

D027 1,4-Dichlorobenzene 7 .5 D015 Toxaphene 0 .5

D028 1,2-Dichloroethane 0 .5 D040 Trichloroethylene 0 .5

D029 1,1-Dichloroethylene 0 .7 D041 2,4,5-Trichlorophenol 400 .0

D030 2,4-Dinitrotolene 0 .13 D042 2,4,6-Trichlorophenol 2 .0

D012 Endrin 0 .02 D017 2,4,5-TP (Silvex) 1 .0

D013 Heptachlor (& its hydroxide)

0 .008 D043 Vinyl Chloride 0 .2

(TABLE 2)TOXIC HAZARDOUS WASTE AND TCLP THRESHOLDS

(TABLE 1)F-LIST HAZARDOUS WASTES

Waste Code Waste Stream

F001 – F005 Spent solvents

F006 – F009 Electroplating waste

F010 – F012, F019 Metal heat treating waste

F020 – F023, F026 – F028 Dioxin-bearing waste

F024, F025 Chlorinated aliphatic hydrocarbons

F032, F034, F035 Wood preserving waste

F037, F038 Petroleum refinery waste

F039 Multisource leachate



K-List

This list contains wastes from specific industrial sources, such as from the manufacture of organic and inorganic chemicals . These wastes are not generated in hospital or university settings .

P- and U-Lists

Both of these lists apply to unused chemicals such as those that are no longer needed, have exceeded their shelf life, spill residue, or residue remaining in the product container . What distinguishes the P-list from the U-list is their degree of danger . Products on the P-list are acutely hazardous, while most of those on the U-list are toxic.

The P and U- lists apply to the specifically listed unused chemicals. For mixtures and formulations, the listings only apply when a single chemical on one of these lists is the only active ingredient . Examples of P- and U-list waste are shown in Tables 3 and 4 . The complete lists are at 40 CFR 261 .33 .

Drug packages are considered hazardous waste if they formerly held any P- or U- list chemicals and if they are not empty. Empty is defined differently for each of these lists. Packages that formerly held P-list commercial chemical products are empty if they have been triple rinsed with a suitable solvent. Although it might be feasible to rinse bottles and similar containers, it might not be feasible to rinse foil or plastic packages. Therefore, it is usually more convenient to manage the container itself as P-list waste.

The rinsate must be managed as P-list hazardous waste unless it can be used on-site for its intended purpose or discharged as wastewater in accordance with the facility’s wastewater discharge permit .

Packages that formerly held U-list commercial chemical products are empty after they have been emptied to the best of your ability, using your conventional methods, and they contain less than one inch of residue or less than three percent by weight .

(TABLE 3)P-LIST PHARMACEUTICAL


P001 Warfarin > 0 .3%

P012 Arsenic trioxide

P042 Epinephrine*

P046 Phentermine

P081 Nitroglycerin (R)**

P188 Physostigmine salicylate

P204 Physostigmine

* This listing refers to epinephrine, with the CAS number 51-43-4 . Hospitals

primarily use epinephrine salts that are assigned various other CAS

numbers . The EPA issued an interpretation in October 2007 indicating

that the salts are not P042 waste . However, you should check with your

state environmental agency to determine if it follows EPA’s interpretation .

**When listed wastes are annotated with an I, C, or R in parentheses, this

indicates that the waste is subject to the hazardous waste regulations

when the waste displays the ignitability, corrosivity, or reactivity

characteristics . Nitroglycerin patches, for example, typically do not display

the characteristic of reactivity .

(TABLE 4)U-LIST PHARMACEUTICAL


U010 Mitomycin C

U034 Chloral hydrate

U035 Chlorambucil

U058 Cyclophosphamide

U059 Daunomycin

U129 Lindane

U150 Melphalan

U202 Saccharin

P204 Physostigmine

U205 Selenium sulfide

U206 Streptozotocin

U237 Uracil mustard

U248 Warfarin & salts > 0 .2%



Temporary Accumulation of Hazardous WasteThe locations in which large and small quantity generators accumulate hazardous waste are known as satellite accumulation points and central accumulation points. Although conditionally exempt facilities need not establish these areas, these facilities find that it is an efficient way to accumulate their wastes .

Satellite Accumulation

You can accumulate up to 55 gallons of hazardous waste or up to one quart of acute hazardous waste at or near any point where hazardous waste is generated. You can, for example, establish hazardous waste accumulation containers in each lab, at nurses’ stations, and in the pharmacy . These satellite containers must also be located in an area that is under the control of the personnel who generated the waste.

Satellite waste containers must be in good condition, compatible with the waste, and must be marked with the name of their contents and/or with the words “Hazardous Waste.” These containers must be kept closed at all times. In most states, there is no time limit, however if you exceed 55 gallons in a satellite area or, one quart of acutely hazardous waste, you must date the container and move it to one of your central accumulation points .

Central Accumulation

You can accumulate an unlimited amount of hazardous waste at a central accumulation area for up to 90 days if

your facility is a large quantity generator and up to 180 days if your facility is a small quantity generator (as well as up to 270 days if your waste is shipped more than 200 miles).The requirements for this area are similar to those that apply to satellites, but are more comprehensive . At a central accumulation area, you must:

• Handle hazardous waste in a manner that avoids ruptures or releases

• Inspect the area at least weekly, looking for signs of leakage and deterioration

• Ensure that the words “Hazardous Waste” are visible on each container

• Have adequate aisle space for access during weekly inspections and for emergency equipment access

• Ensure that incompatibles are adequately separated

• Store ignitable and reactive wastes safely

- at least 50 feet inside your facility boundary

- in a manner that prevents generation of heat, pressure, explosion, dangerous fumes, mists, dusts, or that could damage the integrity of the container

Both large and small quantity generators must prepare for emergencies by having communication devices, fire control equipment, and spill control equipment that is suitable for the types of incidents that could occur . They must designate an emergency coordinator who is available on-site or is on-call at all times . Small quantity generators must post the name, phone number, and address of the emergency coordinator at phones near where hazardous waste is accumulated . Large quantity generators must have a written contingency plan that spells out the responsibilities of the emergency coordinator, the site’s hazardous waste emergency procedures, and identifies the name, location, and capabilities of the site’s emergency equipment .

Off-site TransportationBefore hazardous waste can be shipped off-site, it must be placed in containers that meet U.S. Department of Transportation requirements, a hazardous waste manifest must be prepared, and you must specify the appropriate placard for the waste transporter. This can be an arduous procedure for a novice, but is not difficult for anyone who has received DOT hazardous material training . Personnel who perform any of the following job functions must be trained and tested at least every three years so that they know how to: safely prepare hazardous waste (or other hazardous materials) for shipment, select containers, place hazardous waste into containers, mark or label containers, fill out or sign hazardous waste manifests, load hazardous waste onto vehicles, or specify the placard required on the transport vehicle .

Generator StatusDepending on the amount of hazardous waste generated at your facility, you could be a conditionally exempt, small, or large quantity generator . The scope of the regulations increases along with the amount of hazardous waste you generate . Use Table 5 to determine your site’s generator status .

(TABLE 5)GENERATOR STATUS

Large Quantity Generator

> 1000 kg (2,205 lb .) non-acute hazardous waste

>1 kg acute hazardous waste

Small Quantity Generator

> 100 kg but < 1000 kg (220 – 2,205 lb .)

<1 kg acute hazardous waste

Conditionally Exempt Generator

< 100 kg (220 lb .) hazardous waste

<1 kg acute hazardous waste



Containers Used for Waste Transportation

To identify an appropriate container for hazardous waste transportation, follow these steps:

1 . Locate the proper shipping name of the waste in column 2 of the hazardous materials table at 49 CFR 172 .101

2 . Find the regulatory reference specified for non-bulk packages in column 8(b) of the table . This will be a three digit number that will replace the Xs in 49 CFR 173 .XXX .

3 . Review the 49 CFR 173 .XXX citation for a list of authorized containers

4 . You can use any of the listed containers, provided that they are compatible with the waste you place in the container and the container is filled and sealed in accordance with its manufacturer’s instructions

Hazardous Waste Manifest

The hazardous waste manifest is a document that accompanies your waste from your facility to the hazardous waste treatment, storage, or disposal facility that you have selected for your waste . It identifies your site as the waste generator; the transporter that carries your waste off-site; and the destination hazardous waste treatment, storage, disposal, or recycling facility . The manifest is required for off-site shipments from facilities classified as large or small quantity generators . The manifest is not required for, but is commonly used by conditionally exempt small quantity generators .

As the generator of the waste, you are responsible for the completeness and accuracy of the information entered on the manifest. Some of the key information on the manifest includes:

• The DOT basic description of the waste, which includes the following information obtained from the hazardous mate-rial table at 49 CFR 172 .101: proper shipping name, hazard class, identification number, and packing group .

• The notation “RQ” added to each basic description for wastes shipped in an amount of at least its reportable quantity . Reportable quantities are listed in 49 CFR 172 .101 Appendix A .

• The total quantity of each waste type, together with the type of container, and the EPA hazardous waste code .

• A certification indicating that the waste is identified, packed, marked, and labeled in accordance with applicable regulations .

• A certification indicating that your facility is implementing a waste minimization program

• The signature of a designated person at your facility indicating that the above information is accurate . The person who signs the certification must have completed DOT hazardous materials training .

Land Disposal Notice

Most hazardous wastes have been banned from land disposal. Instead, the waste must be treated to meet treatment standards established by the EPA . Hazardous waste generators must notify the facilities to which they ship their waste that the waste is subject to the land disposal restrictions and that the waste cannot be land disposed unless it meets the treatment standard designated by EPA for the waste . Most companies that transport hazardous waste provide waste generators with a land disposal notice form to prepare or, the transporter provides a land disposal notice form that is pre-prepared for the generator’s waste streams . The treatment standards can vary depending on the waste, its subcategory, and treatability group . Some of the treatment standards are technology based – requiring a specific method of treatment such as incineration, while others are concentration based – allowing any form of treatment except dilution .

Vehicle Loading

After you’ve taken great strides to safely manage your hazardous waste while it is stored on-site, you must also ensure that it is safely handled when it is shipped off-site . Critical questions to answer include:

• Are the waste containers sealed in accordance with the manufacturer’s instructions?

• Are the waste containers secured on the transporter’s vehicle?

• Have we confirmed that there are no incompatible materials loaded on the transporter’s vehicle? (see the compatibility chart at 49 CFR 177 .848)



STATE SPECIFIC CLASSIFICATIONS

California Under California’s Medical Waste Management Act, pharmaceuticals that are not classified as hazardous waste under the federal RCRA program are classified as “California-Only Hazardous Wastes .” These state-regulated wastes are subject to the Department of Health Services regulations . An HYPERLINK “http://www .cwea .org/ihw/documents/DHS Guidance Pharmacy Waste from Hospitals .pdf” October 22, 2002 Memo from Jack McGurk, Chief of the DHS Envi-ronmental Branch provided the regulated community with guidance on meeting the DHS standards, which is summarized below .

• Generators of pharmaceutical medical waste must develop and implement a plan and procedure for properly managing and disposing of pharmaceuticals .

• Staff must be trained in the implementation of the plan and procedure

• California-only hazardous waste pharmaceuticals must be treated by incineration

• Federally-regulated pharmaceuticals are subject to the full scope of the federal and state hazardous waste regulations

Florida Florida classifies hazardous waste pharmaceuticals as universal waste . When managed as universal wastes, the following requirements apply:

• Containers used to store waste pharmaceuticals must be compatible with the waste and be kept closed .

• Keep incompatible pharmaceuticals segregated and adequate distance apart to prevent them from reacting with each other .

• Containers must be marked with the phrase “universal pharmaceutical waste” or “universal waste pharmaceuticals,” and with specific hazardous waste codes applicable to the universal pharmaceutical waste

• Employees handling or managing universal pharmaceutical waste must receive annual classroom or on-the-job training on proper waste management procedures and emergencies

• Prior to sending a shipment of universal pharmaceutical waste, the waste generator must ensure that the destination facility agrees in writing to receive the shipment

• Records of waste shipments, such as manifests or bills of lading must be kept for at least three years

Michigan In Michigan, the Department of Environmental Quality has expanded the federal list of hazardous waste to include severely toxic wastes that contain aflatoxin, tetrachlorodibenzofuran, and several dioxin-bearing wastes .

Central accumulation areas holding liquid or acute hazardous waste must be equipped with containment, and containers at satellite accumulation points must be marked with their waste codes and the words “Hazardous Waste .”

Michigan classifies hazardous waste pharmaceuticals as universal waste . When managed as universal wastes, the following requirements apply:

• Keep incompatible pharmaceuticals segregated and adequate distance apart to prevent them from reacting with each other .

• Keep original labels on containers . If original label is not readable or available, add a label identifying the contents, or you may label them “Universal Waste Pharmaceutical”

• Do not put unwanted drugs in medical waste red bags or sharps containers .

• Do not burn the drugs or flush the drugs down the drain .

• If the unwanted drugs are liquids, they are also subject to the HYPERLINK “http://www .legislature .mi .gov/(avvlzo55bzikei-45elj43dm5)/mileg .aspx?page=getobject&objectname=mcl- 451-1994-ii-3-121&highlight=” Part 121 liquid industrial waste regulations when shipped in Michigan

Oregon The Oregon Department of Environmental Quality has expanded the scope of hazardous waste in the state by including several wastes not covered by EPA, these include mixtures containing at least 3% Federal P-List waste or 10% Federal U-list waste, nerve agents such as Sarin and VX, pesticides and their residues if they have a LC50 of not more than 250 mg/l, and certain blister agents, such as mustard gas .

Accumulation points at sites that store over 100 containers of hazardous waste must be protected by a containment system, unless there are no free liquids in the waste and no wastes bearing the waste codes F020, F021, F022, F023, F026, or F027 are stored . Washington The Department of Ecology regulations for dangerous waste include several wastes that are not included in the US EPA hazardous waste regulations . These include wastes that have an oral LD50, aquatic LC50, inhalation LC50 dermal LD50 less than or equal to certain thresholds . A formula is used to determine the toxic category based on the toxicity of the constituents of the waste, with Category X being the most toxic, followed by less toxic categories A, B, C, and D . Also, PCBs, halogenated hydrocarbons and polycyclic aromatic hydrocarbons are designated as hazardous waste .

The state has several requirements for the on-site storage of hazardous waste that go beyond the federal requirements . These include a requirement to store reactive wastes in accordance with the Uniform Fire Code, a minimum 30-inch aisle space between hazardous waste containers, as well as a requirement to have adequate containment at accumulation points (however containment is not mandatory at satellite accumulation areas) .

Pesticides cannot be managed as universal waste in Washington .



CONSEQUENCES OF NONCOMPLIANCE

The primary objective of the hazardous waste regulations is to protect the environment

and human health from the dangers of hazardous waste. The primary consequence of

non-compliance is environmental deterioration which ultimately impacts our health and well being .

Noncompliance can also result in monetary fines and imprisonment. The EPA has the

authority to assess civil penalties of up to $37,500 per day per violation, and up to

$1,000,000 for each criminal violation of the law. Moreover, violators can be assessed jail

terms of ten years or more, depending on the severity of the violation . Each state environmental

agency has similar enforcement authority .

IN CONCLUSION

While the management of hazardous pharmaceuticals is required by the regulations, the appropriate

disposal of non-hazardous pharmaceuticals is a Best Demonstrated Practice — managing all of your

pharmaceutical waste to assure that pharmaceuticals will not enter the water .

Stericycle provides you with Comprehensive Solutions to assure that your facility is compliant.

When you need an answer for your Pharmaceutical Waste, we can provide the solution.

To find out more Information please call (866) 783-7422

Rx Compliance

Rx Inventory

DISPENSED TO PATIENT

1 2

WHAT HAPPENS TO Rx INVENTORY IN A HEALTHCARE FAC IL I TY?

DECLARED WASTE



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Documents

Hazardous Drug Disposal Serviceresearch.tu.edu/biosafety/PharmacueticalWasteManagementWhiteP… · hospital’s formulary can be classified as hazardous waste. To identify which of