One of the ramifications of mismanagement of unused medications is the environmental effects resulting from poor pharmaceutical disposal practices. Through the years, pharmaceuticals have been largely discarded through either flushing or “sinking” them into the wastewater stream or discarding them into the solid waste stream. In the first instance, the wastewater is treated to remove physical, chemical, and biological contaminants, such as sediment, bacteria, and viruses. However, this treatment does not remove all organic molecules, which are inherent in pharmaceuticals. Thus, many of these molecules remain entrained in the treated waste water which is discharged into reservoirs, rivers, or lakes. Likewise, drugs disposed of as solid waste (into landfills) may leach these organic molecules into aquifers and into the fresh water supply.
Once these “trace drugs” are in the water supply, they present dangers to aquatic life. Dangers also result from water being collected for treatment at water treatment plants and then piped to consumers. Most treatment plants are not designed to remove all drug residue.
The Environmental Protection Agency established the Resource Conservation and Recovery Act, commonly referred to as RCRA, in 1976. RCRA is the federal law that governs the disposal of solid and hazardous wastes. Discarded pharmaceuticals are solid wastes, and it is estimated that between 5% and 10% are also classified as hazardous wastes when discarded.
Under the current federal hazardous waste regulations, until a pharmaceutical is actually discarded, or the decision is made to discard the material, the pharmaceutical is not subject to the RCRA hazardous waste regulations — since a material must first be a solid waste before it can be considered a hazardous waste. When a pharmaceutical is no longer usable, or the decision is made by the generator to discard the material, the RCRA regulations apply, and the generator must determine whether the waste is a RCRA hazardous waste. When faced with the question of whether or not a waste is regulated as hazardous under RCRA, turn to 40 CFR 262.11. This regulation will remind you of the four steps in the RCRA hazardous waste identification process.
Hazardous Waste Types
Listed Wastes – Wastes that EPA has determined are hazardous. The lists include the F-list (wastes from common manufacturing and industrial processes), K-list (wastes from specific industries), and P- and U-lists (wastes from commercial chemical products).
Characteristic Wastes – Wastes that do not meet any of the listings above but that exhibit ignitability, corrosivity, reactivity, or toxicity.
Universal Waste– Batteries, pesticides, mercury-containing equipment (e.g., thermostats), and lamps (e.g., fluorescent bulbs).
Mixed Wastes – Waste that contains both radioactive and hazardous waste components.
Verify whether the discarded pharmaceutical waste appears on any of the hazardous waste lists and/or exhibits at least one of the four characteristics, and if it does, manage it under RCRA subtitle C hazardous waste regulations.
Because of the size of our current pharmacopeia and the many different formulations, dosages and modes of administration of these many drugs, healthcare facilities often face a daunting task when attempting to properly classify their waste pharmaceuticals for disposal purposes. The EPA believes many healthcare-related facilities are unaware of their RCRA obligations. RCRA hazardous waste management requirements often are unfamiliar to healthcare workers, retail pharmacists, and other generators prompting them to dispose improperly of hazardous pharmaceutical wastes as municipal or bulk wastes.