Hazardous Waste at Retail Pharmacies

Last updated on October 30, 2019

There has been increased scrutiny of the generation of hazardous waste in the retail industry – especially in the pharmacy area of stores. The importance of correctly managing the disposal of pharmaceuticals has become a critical issue. There is a category of waste that describes chemicals and constituents that are harmful to the environment – and these materials are classified as hazardous wastes under the Resource Conservation and Recovery Act (RCRA). A number of drugs and pharmaceutical formulations meet the definition of hazardous waste when discarded – and in some cases the empty containers that these pharmaceuticals came in may also need to be managed as hazardous waste.

Whoa, you might say – people are putting these drugs into their bodies? How can a drug like Warfarin be considered acutely hazardous? What about epinephrine, nicotine and nitroglycerin (well, I guess we could understand nitroglycerin if we ever watched the Coyote and Road Runner)? But really, how can these and other pharmaceuticals be considered hazardous waste? The EPA has classified wastes as hazardous under some very strict guidelines that are scientifically verifiable values through testing – based on concentrations and the ability to harm a living organism.

If we look at the “toxic” chemicals, the P-listed and U-listed EPA wastes, we see that these are unused chemicals with a single active ingredient. Any chemical which has been used for its intended purpose does not meet a P or U listing. The P-listed are the most common HW in retail pharmacies (with P-listed Coumadin and Warfarin empty bottles and debris the largest HW volume). The EPA conducted research and determined that these “chemical ingredients” cause harm. If that active ingredient is in a pharmaceutical that is unused, it necessarily becomes a hazardous waste by reference – not necessarily because introducing it into your body will cause you harm.

So, Warfarin is a commonly prescribed pharmaceutical for blood thinning or the reduction of clotting of the blood. In higher concentrations than pharmaceutical use, Warfarin is rat poison, causing rats that eat the poison in traps to “bleed out” and die. This was actually the initial use of the chemical.

Sole active ingredient – what does that mean? “Sole active ingredient” means the active ingredient is the only chemically active component for the function of the product. Let’s illustrate this concept. Take the chemical sodium (NA+). This chemical on its own is very reactive, spontaneously combustible – and will catch on fire in the presence of water (will actually spark from moisture in the air in a humid place). Yikes, don’t want that in our hand. Now, let’s look at chlorine (Cl-). This is a highly toxic gas that was actually the first chemical used in chemical warfare (poison gas) in WWI. Don’t want to be around this sole ingredient.

Put the two together, NaCl, and you have something that is stable and great on French fries. Amazing when two chemicals (ingredients) are introduced to each other and bond with each other. Not toxic in this combination – but not necessarily good for you either. But, separately and unused, many chemicals that are “listed” wastes may be the sole active ingredient in a pharmaceutical, albeit in lower concentrations – but still considered a hazardous waste.

Joe Jordan has a Bachelors of Arts degree in Chemistry from Washington and Jefferson College. He is certified in RCRA and DOT as well as 40 Hour HAZWOPER certified. Joe has been in the hazardous waste industry since 1990 and has managed industrial, healthcare, retail, and governmental clients, both large and small.

published in Hazardous WasteTagged