Non-household Pharmaceutical Waste

Many businesses and institutions have gotten into the habit of flushing unused pharmaceuticals down the toilet because it is convenient, low cost and appears to satisfy regulation against diversion of controlled substances. Proper disposal is not that simple!

Disposal Options for Non-household Pharmaceutical Waste

Options for managing and disposing pharmaceuticals depend in part on what is being disposed, who is generating the waste and who is managing it. In general, DNR recommends businesses and institutions consider the following:

Reuse is an option for some drugs. State law allows nursing homes, assisted living facilities and jails to return certain medications to the dispensing pharmacy. Consult your pharmacy to determine whether this is possible for you. In addition, Wisconsin law allows certain pharmacies to take back unit doses of drugs for cancer and chronic diseases. Additional information can be found on the Cancer Drug Repository [exit DNR] Web page.
Return to the manufacturer is an option for businesses and institutions when drugs are eligible for credits or rebates. This is typically done using a "reverse distributor." Waste and waste-like items, however, may not be sent to a reverse distributor.
Incineration is often the best option for businesses and institutions, provided it is done properly and is allowed under the incinerator's permit. Hazardous waste incineration must be used for hazardous wastes such as chemotherapy waste. Non-hazardous waste such as trace chemotherapy waste, non-hazardous medications and personal care products may go to a medical waste incinerator. Infectious waste may also go to a medical waste incinerator; however, do not mix infectious waste and pharmaceuticals (additional information regarding proper infectious waste disposal is provided below).
Land disposal is legal for businesses and institutions ONLY when the waste is not a controlled substance, hazardous waste or infectious waste.

Why Pharmaceuticals Don't Belong in Infectious Waste Containers

Unless there is a sharp involved, waste pharmaceuticals must be managed separately from infectious waste for four reasons:

It is illegal under Wisconsin's medical waste rules [exit DNR]. Section NR 526.06, Wis. Adm. Code, prohibits putting anything except infectious waste in infectious waste containers.
It is illegal under Wisconsin's hazardous waste rules [exit DNR]. Some waste drugs are legally considered hazardous waste and must be managed accordingly.
It creates a mixture of wastes, which may be difficult and very expensive to manage. If your medical waste company finds hazardous waste in your infectious waste containers, they may refuse to take the mixture. Similarly, your hazardous waste hauler may not accept infectious waste.
There is no guarantee infectious waste will be incinerated. While most infectious waste was incinerated prior to the mid-1990s, most is now disinfected, shredded and landfilled. As noted above, done properly, incineration is the preferred disposal option for pharmaceutical waste.

While some mixing is unavoidable, you should take deliberate steps to minimize these mixtures. If you intend to route pharmaceuticals to an incinerator or other destination, segregate them in their own containers and properly label them.

Reducing Pharmaceutical Waste

It is possible to reduce the amounts of pharmaceuticals that end up being wasted in healthcare facilities. Here are some ideas.

Tighten inventory control by determining if dosage types are redundant and might be consolidated.
Rotate stock to reduce the number of medications that expire before being used.
Pre-label multi-dose items (such as inhalers and ointments) as take-home medications.
Use single dose vials of chemotherapy drugs instead of multiple dose vials.
Use patient-specific oral syringes vs. 10 cc repacks (e.g., chloral hydrate).
Minimize or eliminate the use of samples. Use a voucher system instead.
Use alternate packaging for P-listed medications to reduce the weight of empty containers that must be managed as hazardous waste.
Make a list of the top 10 items you send to reverse distribution and find ways to reduce the number of returns.

For more information, see Reducing Pharmaceutical Waste from Patient Care Settings [exit DNR] offered by the Minnesota Technical Assistance Program or visit EPA's Healthcare Environmental Resource Center [exit DNR] (HERC) and search for the document Managing Pharmaceutical Waste: A 10 Step Blueprint for Health Care Facilities in the United States. Step 5 of this document discusses 11 ways to reduce pharmaceutical waste.

Special Considerations

Epinephrine

Until recently, all epinephrine wastes, including empty containers, were classified as P042 hazardous wastes when disposed. However, several EPA regions, states and others requested that EPA clarify whether the P042 listing included epinephrine salts, which are widely used in healthcare. On October 15, 2007, EPA issued an interpretation stating that the scope of the P042 listing does not include epinephrine salts.

On December 5, 2007, DNR adopted the EPA interpretation with four caveats. DNR's memorandum [PDF 2MB] includes a copy of the EPA's October 15, 2007, interpretation and reminds generators of best management practices and regulatory obligations that apply to epinephrine salt waste. By adopting this interpretation, DNR's regulation of epinephrine and epinephrine salts is aligned with the federal requirements.

In practical terms, this decision means that most epinephrine waste from healthcare is no longer regulated as P042 listed hazardous waste. However, generators still need to:

determine whether each waste is a hazardous waste or not;
determine whether each waste is an infectious waste or not;
check with wastewater authorities to see if each waste may be discarded to the sewer;
correctly determine their generator status; and
report their generator status to DNR if required to do so.

After doing the above, some healthcare facilities may find that this regulatory change relieves them of paperwork, training and other hazardous waste requirements.

Lastly, even though this decision may open up other options for disposing of certain epinephrine wastes, DNR continues to recommend that all waste pharmaceuticals, including non-hazardous epinephrine salt waste, be incinerated.

Bulk Chemotherapy Waste

Only about eight chemotherapy agents are listed as hazardous wastes under state and federal hazardous waste rules. Even so, DNR strongly recommends as a best management practice that all bulk and mixed chemo waste be managed as hazardous waste, destined for incineration or other very high temperature destruction. Do not treat these wastes on-site or send them to an infectious waste treatment facility that disinfects waste with chemicals or steam (e.g., autoclave, microwave, radiowave facilities). See Managing Chemotherapy Waste (PUB WA1258) [PDF 115KB].

Trace Chemotherapy Waste

This waste is defined in s. NR500.03(237m) [exit DNR], and must be managed according to s. NR 526.055 [exit DNR]. In general, trace chemotherapy waste must be incinerated. See Managing Chemotherapy Waste (PUB WA1258) [PDF 115KB].

Transportation

Since August 2006, ch. NR 663, Wis. Adm. Code, allows a person ("transporter") to transport waste without the use of manifests and without getting a hazardous waste transportation license, provided that the waste is transported exclusively from a very small quantity generator (VSQG). Otherwise, the transporter must have a license and must use manifests. An alternative would be to contract with an already licensed hazardous waste transporter (see the Hazardous Waste Transporter Facility List). For more information about waste transportation requirements, contact your local DNR environmental program associate. In addition, federal Department of Transportation [exit DNR] regulations may also apply.

Rules, Resources and Technical Assistance for Non-household Pharmaceutical Waste Disposal

Rules

Businesses and institutions disposing of pharmaceutical waste must follow rules adopted by the Wisconsin DNR, the federal Department of Transportation [exit DNR], the federal Drug Enforcement Administration [exit DNR] and others.

Besides the environmental reasons described in Pharmaceutical Waste, flushing certain drugs may be illegal. Businesses and institutions must comply with:

their local sewer use ordinances and permits; and
Wisconsin statutes [exit DNR];
Wisconsin administrative codes [exit DNR] that may apply include (this is not an exhaustive list):

Solid waste disposal rules, ch. NR 500 series;
Medical waste rule, ch. NR 526. Definitions are in s. NR 500.03, processing facility requirements in s. NR 502.08 and fees in ch. NR 520;
Hazardous waste rules, ch. NR 600 series, particularly chs. NR 660 to 662;
Wastewater rules, ch. NR 211, including s. NR 211.10 (prohibited discharge standards), s. NR 211.15(6) (notice of substantial change in discharge) and s. NR 211.17 (hazardous waste discharge report); and
Mercury reduction rule, ch. NR 106.

Resources and Technical Assistance

Since August 2006, Wisconsin's rules have become more similar to the federal rules in both content and form. If you have specific questions about Wisconsin's requirements, please refer to DNR waste program publications and to the administrative rules listed below, or call your local DNR hazardous waste specialist.

Contact Information

For questions and comments about non-household pharmaceutical waste, contact:

DNR Waste Materials@Wisconsin.gov

Last Revised: Tuesday December 08 2009