EPA Rule on Pharmaceutical Hazardous Waste Disposal

The U.S. Environmental Protection Agency (EPA) finalized a rule, to take effect on August 21^st, which will prohibit healthcare facilities, including dental offices, to “sewer” pharmaceutical hazardous waste. The term “sewering” refers to disposing of pharmaceutical hazardous waste by dumping it down the sewer drains.  

The updated rule applies to pharmaceutical waste that falls under the Federal Resource Conservation and Recovery Act (RCRA) of 1976 and is therefore considered federal hazardous waste. This waste includes bulk chemotherapy drugs, P-listed waste (nicotine, Coumadin/warfarin, arsenic trioxide, etc.), U-listed waste (chloroform) and characteristic hazardous waste (aerosol propellants, M-Cresol, etc.).  Dental amalgam and sharps are not classified as pharmaceuticals under EPA’s Final Rule. 

For pharmaceutical wastes that must be disposed of via reverse distributors, dental offices should continue to dispose of the wastes in this manner. Reverse distributors are entities that help healthcare facilities calculate and receive credit from pharmaceutical manufacturers when healthcare facilities have unused pharmaceuticals that are expired or they no longer need.

Be aware that states may have more restrictive rules for the disposal of nonhazardous, non-RCRA waste with requirements beyond what is found in the EPA’s Final Rule. For example, in California, all pharmaceutical waste that doesn’t fall under the definition of RCRA waste (i.e. non-RCRA) cannot be disposed of in the trash or down the sewer, but must be disposed of as regulated medical waste. 

For our OSHA Review subscribers…the March/April 2017 issue of OSHA Review in Section IX of your OSHA Review binder covers medical waste management in California, including how to dispose of pharmaceutical waste.

Since 1992, OSHA Review, Inc. has provided dental professionals with comprehensive programs to support regulatory compliance and infection control. We are a registered continuing education provider in the state of California, specializing in Dental Practice Act, infection control, and OSHA training.