WA Dept. of Ecology updates pharmaceutical waste policy

  |   State Regulatory

In anticipation of a new federal rule from the Environmental Protection Agency (EPA), the state of Washington is updating their “interim enforcement policy” for managing pharmaceutical waste. This revised policy will give hospitals, clinics, pharmacies, veterinarians, dentists, and other businesses options for how they can dispose of leftover and other unused medications.  The EPA recently proposed new requirements that effectively ban the disposal of pharmaceuticals down the toilet or drain. The federal proposal has not been finalized and may still change slightly but Ecology believes the final federal rules will look very similar to the proposal. Ecology will not adopt a final state rule until EPA finalizes the new federal rules.

The policy covers all dangerous waste pharmaceuticals, defined as “drugs” by the Revised Code of Washington (RCW) 69.04.009. Facilities may not use this policy for non-pharmaceutical waste (including disinfectants), radioactive pharmaceutical waste, or anesthesia gases.

Under the new policy, eligible facilities will need to do six things to be in compliance:

  1. Profile your pharmaceutical waste and send it to Ecology
  2. Notify Ecology you are going to follow the policy instead of the full Dangerous Waste Regulations
  3. Train your staff about the policy and how to handle pharmaceutical wastes properly
  4. Follow certain standards for accumulating pharmaceutical waste
  5. Dispose of pharmaceutical waste as required by the policy
  6. Keep appropriate records

No dangerous waste pharmaceutical can go to the sewer. This includes partially administered controlled substances. You must manage all of your pharmaceutical waste according to this policy or according to the dangerous waste regulations, even if those pharmaceuticals are also listed on a schedule of controlled substances by the DEA.

Containers that once held pharmaceuticals may also be pharmaceutical waste. Disposal requirements are based on whether the container is considered “empty” or not. Except for DEA controlled substances, you can only use a reverse distributor under this policy for “creditable pharmaceuticals.” Creditable pharmaceuticals are those that “can be used for its intended purpose or returned to a manufacturer, wholesaler, or reverse distributor for credit…”

For the complete policy, download the PDF version here.

Additional resources are available on the WA Dept. of Ecology website.