Safe disposal of non-household pharmaceutical waste
This page will help businesses and institutions (including schools and prisons) to manage and reduce their pharmaceutical waste. Guidelines for properly managing pharmaceutical waste differ depending on where the waste is created, handled and disposed of. Some residential health care facilities may qualify as households.
All businesses and institutions that generate pharmaceutical waste are responsible for disposing of that waste according to state and federal law. Given the wide variety of pharmaceutical wastes, complying with those laws can be daunting. The following three resources will help you get started, in addition to the information in the tabs below.
- Evaluating and Managing Pharmaceutical Waste (WA-1257) (under revision)
- Table of Common Wastes in Healthcare (WA-1259)
- Managing Pharmaceutical Waste: A 10-Step Blueprint for Healthcare
The U.S. Drug Enforcement Administration has released rules that affect the disposal of pharmaceutical waste.
Recommended disposal options
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 of pharmaceuticals depend on what is being disposed of, who is creating the waste and who is handling it. In general, the DNR recommends facilities consider the following options.
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.
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.
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.
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.
- 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.
- It is illegal under Wisconsin's hazardous waste rules. Some waste drugs are legally considered hazardous waste and must be managed accordingly.
- Mixing pharmaceutical and infectious waste creates a mixture of wastes that 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.
Transporting pharmaceuticals that are hazardous waste
If you are transporting waste exclusively from a very small quantity generator, you may transport hazardous waste without the use of manifests and without getting a hazardous waste transportation license.
For all other cases, the transporter must have a license and must use manifests.
- Lists of licensed transporters and information on obtaining a hazardous waste transporter license
- U.S. Department of Transportation regulations
DNR interpretations on epinephrine disposal
Until recently, all epinephrine wastes, including empty containers, were classified as P042 hazardous wastes when disposed of. 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.
The DNR has adopted the EPA interpretation with four caveats. DNR's memorandum 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 for managing waste pharmaceuticals
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 the requirements of other agencies, such as the federal Drug Enforcement Administration.
Besides environmental reasons, flushing certain drugs may be illegal. Businesses must comply with:
- their local sewer use ordinances and permits;
- Wisconsin statutes
- Wisconsin administrative codes that may apply include:
- 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.
Reducing pharmaceutical waste
Healthcare facilities can do a lot to reduce the amounts of pharmaceuticals that end up as waste. For example, you may do the following:
- Tighten inventory control to consolidate redundant dosage types.
- Rotate stock so medications get used before they expire.
- Pre-label multi-dose items (such as inhalers and ointments) as take-home medications.
- Minimize or eliminate samples by donating unexpired samples or by using a voucher system.
For more information, visit the following:
DNR publications related to pharmaceutical waste
- Table of Common Wastes in Healthcare (WA-1259)
- Managing Empty Containers (WA-1256) (under revision)
- Pharmaceutical waste at non-hospital health care facilities (WA-1214) (under revision)
Technical assistance for proper pharmaceutical waste management
- U.S. EPA Management of Pharmaceutical Hazardous Waste
- Healthcare Environmental Resource Center Waste Reduction - Pharmaceuticals
- Practice Greenhealth
- Minnesota Technical Assistance Program (Note that Minnesota's requirements differ from Wisconsin's.)
- NIOSH Hazardous Drug Alert See Appendix A
- ASHP Guidance on Handling Hazardous Drugs Search for "handling hazardous drugs"
- OSHA Technical Manual "Controlling Occupational Exposure to Hazardous Drugs"
- How to Dispose of Unwanted Medicine and Personal Care Products (Illinois - Indiana Sea Grant)