Proper Disposal of Epinephrine

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Proper disposal of epinephrine can be very confusing due to the categorization of the drug. By definition, epinephrine is listed specifically as hazardous waste under the EPA Resource Conservation and Recovery Act (RCRA). It is further categorized as P-listed (P042) or Acutely Toxic.

But there’s good news: The EPA has classified most if not all of the epinephrine used in healthcare settings as one of several epinephrine salts. The EPA’s Office of Solid Waste sent a letter to all of its RCRA Division Directors on October 15, 2007 entitled: Scope of Hazardous Waste Listing P042 (Epinephrine). Written in response to inquiries as to whether the hazardous waste listing for epinephrine included epinephrine salts, the memo acknowledges that it is the EPA’s understanding that most if not all of the chemical that is used in healthcare settings is one of several epinephrine salts. The EPA determined that the scope of the P042 listing does not include epinephrine salts. 

Until this clarification, epinephrine salts were classified and handled as RCRA hazardous waste. But now, epinephrine salts can be handled as non-hazardous pharmaceutical waste and sent to a medical waste incinerator or municipal incinerator for treatment. Some states have specific regulations regarding epinephrine, but most states rely on the EPA’s determination.

Many medical waste disposal companies still advise their customers to treat epinephrine as a P-listed RCRA waste. But this practice can be considerably more expensive given the more extensive manifesting and labeling requirements, not to mention the increase in final disposal costs.  

One other consideration is that any facility producing 1kg (2.2 lbs.) of P-listed waste in a calendar month is categorized by the EPA as a large quantity hazardous waste generator. Large quantity generators must follow additional requirements specific to proper management of waste, time and storage limits, training, preparedness and prevention, contingency plans and reporting to regulatory agencies. These facilities must also pay increased fees to regulatory agencies. US Bio-Clean provides expert guidance in the proper categorization, segregation and disposal of pharmaceutical waste, including epinephrine.

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