Non-household pharmaceutical waste

Waste pharmaceuticals include a wide variety of items, such as over-the-counter and prescription medications, controlled substances, and sharps containing medications. These drug wastes come in the form of solid pills and capsules, creams, liquids and aerosols. Many are used in health care facilities and businesses and must be managed properly in these settings.

Guidelines for properly managing pharmaceutical waste differ depending on where the waste is created, handled and disposed. Some residential health care facilities may qualify as households

We strongly recommend all businesses and institutions that generate pharmaceutical waste read Managing Pharmaceutical Waste: A 10-Step Blueprint for Healthcare [exit DNR]. It describes how the U.S. Environmental Protection Agency and the DNR regulate pharmaceutical waste, and offers practical guidance on how to develop a system for managing and reducing pharmaceutical waste in compliance with these regulations. We also recommend reviewing Evaluating and Managing Pharmaceutical Waste (WA-1257) [PDF].

Disposal

Many facilities have gotten into the habit of flushing unused pharmaceuticals down the toilet because it is convenient, low cost and appears to satisfy state and federal regulations. However, proper disposal is not that simple.

Options for managing and disposing pharmaceuticals depend on what is being disposed, who is creating the waste and who is handling it. In general, the DNR recommends facilities consider the following options.

  1. Reuse. 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 Wisconsin Department of Health Services Cancer Drug Repository page [exit DNR].
  2. Return. Returning some drugs to the manufacturer is an option for facilities 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.
  3. Incineration. Incineration is often the best option, provided it is done properly and is allowed under the incinerator's permit. Hazardous waste incineration must be used for 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.
  4. Landfill. Sending waste to a landfill is legal for health care facilities ONLY when the waste is not a controlled substance, hazardous waste or infectious waste.

Pharmaceuticals DO NOT belong in infectious waste containers! Unless there is a sharp involved, waste pharmaceuticals must be managed separately from infectious waste for four reasons.

  1. It is illegal under Wisconsin's health care waste rules. Section NR 526.06, Wis. Adm. Code, prohibits putting anything except infectious waste in infectious waste containers.
  2. It is illegal under Wisconsin's hazardous waste rules. Some waste drugs are legally considered hazardous waste and must be managed accordingly.
  3. Mixing pharmaceutical and infectious waste 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.
  4. 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.

Transportation

Chapter NR 663, Wis. Adm. Code, allows a person or "transporter" to transport hazardous 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 [PDF]. For more information about waste transportation requirements, contact your local DNR environmental program associate. In addition, federal Department of Transportation regulations [exit DNR] may also apply.

Special disposal considerations

DNR interpretations on epinephrine disposal

Until recently, all epinephrine wastes, including empty containers, were classified as P042 hazardous wastes when disposed. However, several U.S. Environmental Protection Agency (EPA) regions, states and others requested that EPA clarify whether the P042 listing included epinephrine salts, which are widely used in health care. In October 2007, the EPA issued an interpretation stating that the scope of the P042 listing does not include epinephrine salts.

In December 2007, the DNR adopted the EPA interpretation with four caveats. DNR's memorandum [PDF] includes a copy of EPA's October 2007 interpretation and reminds generators about 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 federal requirements.

In practical terms, this decision means that most health care epinephrine waste 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 following the above steps, some health care 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, the DNR continues to recommend that all waste pharmaceuticals, including non-hazardous epinephrine salt waste, be incinerated.

Legal requirements

Non-household pharmaceutical waste may fall under the definition of one or more legal waste categories regulated by the DNR. Examples include hazardous wastes of various kinds, solid waste and infectious waste. Flushing pharmaceuticals may violate hazardous waste and wastewater rules. Non-household pharmaceutical waste may also be subject to requirements of other agencies, such as the federal Drug Enforcement Administration.

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.

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

Besides environmental reasons, flushing certain drugs may be illegal. Businesses must comply with:

  • their local sewer use ordinances and permits;
  • 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.

Public school nurses should consult the Department of Public Instruction's guidance on disposal of medications [exit DNR] (Scroll down to Administrative Resources, then look under the Miscellaneous column.)

Environmental impacts

Pharmaceuticals and related compounds have been widely found in wastewater effluent, surface waters and, in limited cases, groundwater. Researchers are now investigating how some pharmaceuticals and personal care products may harm aquatic life. The environmental impacts are as varied as the products involved.

  • Pharmaceuticals and personal care products may contain mercury, selenium and other heavy metals which can pollute our air, land and water.
  • Other pharmaceuticals are endocrine disruptors, which have been implicated with changes in the form, reproduction and sex-ratios of aquatic and other wildlife.
  • Antimicrobial agents such as triclosan may harm beneficial bacteria. Any disease-producing bacteria not killed by the products can develop into antibiotic resistant strains.
  • Burning pharmaceuticals and their containers improperly – e.g. in burn barrels or industrial boilers – can contribute to air pollution. Uncontrolled incineration doesn't destroy drug components and it can create dangerous dioxins.
  • Unused products and empty containers accumulate in our landfills. Drug components that leach out may seep into groundwater or be removed and sent to local wastewater treatment plants.
  • Inappropriate donations of pharmaceuticals may create disposal issues and other environmental problems for the recipients, particularly if the drugs are exported to other countries.

Several DNR publications address pharmaceutical disposal. Under the Waste and Material Management Program's searchable publication system, use the keyword search at the top, then choose the keyword "pharmaceuticals" and then click Find

In addition to the environmental impacts, excess pharmaceuticals directly affect the health and safety of our families and communities through accidental poisonings, medication errors, drug abuse and drug abuse-related crime.

Reducing waste

Reducing pharmaceutical waste

It is possible to reduce the amounts of pharmaceuticals that end up wasted in health care facilities through the following.

  • 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 use.
  • 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 health care Environmental Resource Center [exit DNR] 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.

Resources

DNR publications

Several DNR publications address pharmaceutical disposal. Under the Waste and Material Management Program's searchable publication system, use the "Keyword search" at the top, then choose the keyword "pharmaceuticals" and click "Find." See also publications under the keyword "medical waste" for how to manage medical sharps.

Related websites

Technical assistance

Organizations providing live technical assistance
Last revised: Friday March 15 2013