Pharmaceutical Waste Disposal
Comprehensive Pharmaceutical Waste Management Solutions Nationwide
Pharmaceutical manufacturers, hospitals, clinics, pharmacies, research institutions, and all facilities handling medications generate strictly regulated pharmaceutical waste requiring expert management. From controlled substances and chemotherapy waste to expired medications and laboratory chemicals, Hazardous Waste Disposal provides compliant, secure pharmaceutical waste management services meeting EPA, DEA, and state regulations.
Call (800) 582-4833 for pharmaceutical waste disposal services or email info@hazardouswastedisposal.com
Understanding Pharmaceutical Hazardous Waste
Pharmaceutical waste is regulated under multiple federal and state programs including the Resource Conservation and Recovery Act (RCRA), Drug Enforcement Administration (DEA) Controlled Substances Act, and various state-specific pharmaceutical waste regulations. Proper management requires understanding complex classification systems, segregation requirements, and disposal pathways.
Why Pharmaceutical Waste Requires Specialized Management
Pharmaceutical waste differs from general hazardous waste due to:
Dual Regulatory Oversight: EPA regulates hazardous characteristics while DEA controls scheduled substances. Many pharmaceutical wastes fall under both regulatory frameworks requiring coordinated compliance.
Public Health Protection: Improper disposal can contaminate water supplies, harm wildlife, enable drug diversion, and create public health hazards. The opioid crisis has intensified scrutiny on controlled substance disposal.
Environmental Persistence: Many pharmaceutical compounds don't break down naturally and can accumulate in ecosystems, affecting aquatic life and potentially entering the human food chain.
Security Requirements: Controlled substances require chain-of-custody documentation, witness requirements for destruction, and theft prevention measures during storage and transportation.
Complex Classification: Pharmaceuticals may be hazardous due to ignitability (alcohol-based), reactivity (certain chemotherapy agents), toxicity (heavy metals in some formulations), or listed waste status (specific EPA codes).
Pharmaceutical Waste We Handle
Hazardous Pharmaceutical Waste (RCRA-Regulated)
Chemotherapy and Antineoplastic Drugs
Chemotherapy agents are among the most hazardous pharmaceutical wastes due to their carcinogenic, mutagenic, and teratogenic properties. These cytotoxic drugs require specialized handling and disposal.
Common chemotherapy waste includes:
IV bags containing residual chemotherapy drugs (even empty bags retain drug residue)
Vials and ampules from drug preparation
Syringes used for chemotherapy administration
Administration sets (tubing, connectors, pump cassettes)
Personal protective equipment (PPE) contaminated during handling (gowns, gloves, face shields)
Spill cleanup materials from chemotherapy preparation or administration areas
Expired or unused chemotherapy medications
Compounding waste from pharmacy preparation areas
Major chemotherapy drug categories requiring specialized disposal:
Alkylating agents (cyclophosphamide, cisplatin, carboplatin)
Antimetabolites (methotrexate, 5-fluorouracil, gemcitabine)
Antitumor antibiotics (doxorubicin, bleomycin, mitomycin)
Plant alkaloids and terpenoids (vincristine, vinblastine, paclitaxel, docetaxel)
Topoisomerase inhibitors (etoposide, irinotecan, topotecan)
Monoclonal antibodies (rituximab, trastuzumab, bevacizumab)
Targeted therapy agents (imatinib, erlotinib, sorafenib)
Facilities generating chemotherapy waste:
Major cancer centers: MD Anderson Cancer Center (Houston), Memorial Sloan Kettering Cancer Center (New York), Mayo Clinic (Rochester, Scottsdale, Jacksonville), Dana-Farber Cancer Institute (Boston), Fred Hutchinson Cancer Center (Seattle)
Hospital oncology departments: All major hospital systems including Cleveland Clinic, Johns Hopkins Hospital, Massachusetts General Hospital, UCSF Medical Center
Outpatient infusion centers: Freestanding chemotherapy clinics, physician office-based infusion suites
Compounding pharmacies: Specialized pharmacies preparing IV chemotherapy admixtures
Home healthcare agencies: Providing in-home chemotherapy administration services
Veterinary oncology clinics: Animal hospitals treating cancer in pets
Special handling requirements:
Chemotherapy waste must be segregated at point of generation in clearly marked, leak-proof containers
Yellow chemotherapy waste containers are industry standard for visual identification
EPA waste codes U listed wastes (specific unused commercial chemical products) and P listed (acutely hazardous)
Some states (California, Washington, Minnesota, others) have additional chemotherapy waste requirements
Incineration is typically required for chemotherapy waste disposal
Documentation must track waste from generation through final destruction
Pharmaceutical Manufacturing Waste
Pharmaceutical manufacturers produce hazardous waste throughout drug development, production, quality control, and packaging operations.
Active Pharmaceutical Ingredient (API) Manufacturing Waste:
Reaction vessel cleanouts and purge materials
Off-specification batches not meeting quality standards
Distillation bottoms from purification processes
Filter cakes and spent filter media
Crystallization mother liquors
Solvent recovery waste streams
Synthesis intermediates and byproducts
Expired or degraded raw materials
Process Solvents:
Methanol, ethanol, isopropanol, acetone (Class IC flammable liquids)
Methylene chloride, chloroform (halogenated solvents, suspected carcinogens)
Toluene, xylene, hexane (aromatic and aliphatic hydrocarbons)
Dimethyl sulfoxide (DMSO), dimethylformamide (DMF) (dipolar aprotic solvents)
Tetrahydrofuran (THF), diethyl ether (ether solvents with peroxide formation risk)
Acetonitrile (used extensively in pharmaceutical synthesis and HPLC)
Quality Control Laboratory Waste:
HPLC mobile phases and column waste
Gas chromatography solvents and standards
Mass spectrometry waste
Titration reagents and standards
pH buffers and calibration solutions
Spectrophotometry chemicals
Microbiological culture media (potentially infectious)
Failed stability study samples
Equipment Cleaning Waste:
Clean-in-place (CIP) solutions
Steam-in-place (SIP) condensate (may contain drug residues)
Tank and reactor cleaning solvents
Production line changeover waste
Equipment decommissioning materials
Validation cleaning waste samples
Major pharmaceutical manufacturers we serve:
Pfizer: Multiple manufacturing sites including Kalamazoo MI, Groton CT, Pearl River NY, McPherson KS
Johnson & Johnson/Janssen: New Brunswick NJ, Titusville NJ, and sites nationwide
Merck: Rahway NJ, West Point PA, Durham NC, Wilson NC
Bristol Myers Squibb: New Brunswick NJ, Princeton NJ, Devens MA
AbbVie: North Chicago IL, Worcester MA
Eli Lilly: Indianapolis IN, Research Triangle Park NC
Amgen: Thousand Oaks CA, Cambridge MA, Puerto Rico
Gilead Sciences: Foster City CA, Edmonton Canada operations
Regeneron: Tarrytown NY, Rensselaer NY
Genentech/Roche: South San Francisco CA
Takeda: Cambridge MA, Lexington MA
Novartis: East Hanover NJ, Cambridge MA
Sanofi: Bridgewater NJ, Cambridge MA, Framingham MA
AstraZeneca: Gaithersburg MD, Frederick MD
GlaxoSmithKline: Research Triangle Park NC, Philadelphia PA
Biopharmaceutical and Biotech Waste
Biotechnology and biologics manufacturing creates unique waste streams from cell culture, fermentation, and purification processes.
Bioprocessing Waste:
Expired cell culture media and buffers
Chromatography column waste (protein A columns, ion exchange resins)
Filtration membrane waste
Bioreactor cleaning solutions
Centrifugation waste
Viral inactivation reagents
Monoclonal antibody production waste
Recombinant protein purification waste
Cell Culture Materials:
Fetal bovine serum (FBS) and other animal-derived components
Growth factors and cytokines
Antibiotics used in cell culture (gentamicin, penicillin-streptomycin)
Selection agents (G418, puromycin, hygromycin)
Transfection reagents
Cryopreservation media
Gene Therapy and Advanced Therapy Medicinal Products (ATMP) Waste:
Viral vector production waste
CAR-T cell manufacturing waste
CRISPR/Cas9 gene editing materials
Lentiviral and adenoviral vector waste
Cell therapy processing waste
Major biotech and biologics facilities:
Moderna: Cambridge MA, Norwood MA (mRNA therapeutics and vaccines)
BioNTech: Cambridge MA (mRNA technology)
Vertex Pharmaceuticals: Boston MA (cystic fibrosis and other therapies)
Biogen: Cambridge MA, Research Triangle Park NC (neurology and biosimilars)
Alnylam Pharmaceuticals: Cambridge MA (RNAi therapeutics)
Bluebird Bio: Somerville MA (gene therapy)
Intellia Therapeutics: Cambridge MA (CRISPR/Cas9)
CRISPR Therapeutics: Cambridge MA (gene editing)
Sarepta Therapeutics: Cambridge MA (genetic medicine)
Kite Pharma: Santa Monica CA (CAR-T cell therapy)
Juno Therapeutics: Seattle WA (immunotherapy)
Expired and Unused Medications
Healthcare facilities, pharmacies, long-term care facilities, and manufacturers accumulate expired, damaged, or unused medications requiring compliant disposal.
Categories of expired medications:
Prescription medications (brand name and generic)
Over-the-counter medications
Veterinary pharmaceuticals
Compounded preparations
Clinical trial investigational drugs
Recalled medications
Damaged or contaminated products
Returns from patients and facilities
Common expired medications requiring hazardous waste disposal:
Warfarin (EPA P listed waste - P001, acutely toxic rodenticide)
Physostigmine (EPA P listed waste - P204, highly toxic)
Nicotine patches and products (EPA P listed - P075 in some forms)
Chlorambucil (EPA U listed waste - U035, alkylating agent)
Cyclophosphamide (EPA U listed - U058, chemotherapy)
Lindane (EPA U listed - U129, neurotoxic pesticide)
Mitomycin C (EPA U listed - U010, antineoplastic)
Mercury-containing medications (antiseptics, preservatives)
Arsenic-containing medications (historical use, rare today)
Chromium-containing medications (nutritional supplements)
Non-hazardous pharmaceutical waste: Most expired medications are NOT RCRA hazardous waste but still require proper disposal:
Antibiotics (amoxicillin, azithromycin, ciprofloxacin)
Analgesics (ibuprofen, acetaminophen, non-narcotic pain relievers)
Cardiovascular medications (statins, ACE inhibitors, beta blockers)
Diabetes medications (metformin, insulin)
Antidepressants (SSRIs, SNRIs)
Antihypertensives
Gastrointestinal medications
While not RCRA hazardous, these still require compliant disposal to prevent:
Environmental contamination
Drug diversion and abuse
Accidental pediatric ingestion
Improper use
Controlled Substances (DEA-Regulated)
The Drug Enforcement Administration regulates controlled substances under the Controlled Substances Act. Disposal requires strict compliance with DEA regulations including use of DEA Form 41.
Schedule II Controlled Substances (High abuse potential, accepted medical use):
Opioids: Oxycodone (OxyContin, Percocet), hydrocodone (Vicodin, Norco), morphine, hydromorphone (Dilaudid), oxymorphone (Opana), methadone, fentanyl
Stimulants: Amphetamine (Adderall), methylphenidate (Ritalin, Concerta), dextroamphetamine (Dexedrine)
Cocaine (used medically as topical anesthetic)
Schedule III Controlled Substances:
Combination products with lower opioid doses: Tylenol with codeine, buprenorphine (Suboxone, Subutex)
Ketamine
Anabolic steroids
Schedule IV Controlled Substances:
Benzodiazepines: Alprazolam (Xanax), diazepam (Valium), lorazepam (Ativan), clonazepam (Klonopin), temazepam (Restoril)
Sleep medications: Zolpidem (Ambien), eszopiclone (Lunesta), zaleplon (Sonata)
Tramadol (pain reliever)
Schedule V Controlled Substances:
Cough preparations with small amounts of codeine
Pregabalin (Lyrica)
Lacosamide (Vimpa
t)
DEA disposal requirements:
Authorized DEA registrants required for controlled substance disposal
DEA Form 41 (Registrant's Inventory of Drugs Surrendered) must be completed
Two-witness requirement for on-site destruction or transfer to reverse distributor
Detailed inventory documentation including drug name, strength, quantity, NDC number
Perpetual inventory adjustments
Biennial inventory requirements
Facilities generating controlled substance waste:
Hospitals and health systems: All acute care hospitals maintain controlled substance inventories
Retail pharmacies: CVS, Walgreens, Rite Aid, Walmart, Kroger pharmacies handle returns and expirations
Long-term care facilities: Nursing homes accumulate patient-specific medications when patients expire or leave facility
Hospice providers: Significant unused opioid quantities when patients pass away
Ambulatory surgery centers: Operating room controlled substance waste
Veterinary clinics: Animal controlled substances including ketamine, buprenorphine, controlled anesthetics
Correctional healthcare: Prisons and jails with medical departments
Compounding pharmacies: Specialized facilities preparing controlled substance formulations
Laboratory Chemical Waste from Healthcare Facilities
Hospital and clinical laboratories generate diverse chemical waste from diagnostic testing, pathology, microbiology, and research operations.
Clinical Chemistry Laboratory Waste:
Reagents for automated chemistry analyzers
Calibrators and quality control materials
Acids and bases for pH adjustment
Organic solvents from extraction procedures
Heavy metal standards (lead, mercury, cadmium for blood level testing)
Chromogenic substrates
Enzyme reagents
Hematology and Coagulation Laboratory Waste:
Staining reagents (Wright-Giemsa, special stains)
Lysing reagents for cell counting
Coagulation testing reagents
Hemoglobin standards
Methanol-based fixatives
Microbiology Laboratory Waste:
Culture media (may contain infectious materials)
Antibiotic sensitivity testing reagents
Bacterial identification chemicals
Mycobacterial testing reagents
Fungal culture materials
Parasitology preservatives and stains
Pathology and Histology Laboratory Waste:
Formaldehyde and formalin (tissue fixation) - highly toxic, carcinogenic
Xylene (tissue processing and staining) - flammable, toxic
Alcohols (ethanol, isopropanol) for tissue dehydration
Staining reagents (hematoxylin, eosin, special stains)
Mounting media and solvents
Decalcification solutions (formic acid, nitric acid, EDTA)
Immunohistochemistry reagents
Frozen section embedding media
Blood Bank Laboratory Waste:
Typing and crossmatch reagents
Antibody screening and identification reagents
Quality control materials
Expired blood products (not hazardous waste but require special disposal)
Molecular Diagnostics and Genetics Laboratory Waste:
PCR reagents and master mixes
DNA/RNA extraction chemicals (phenol-chloroform, guanidinium thiocyanate)
Electrophoresis buffers and gels (ethidium bromide, SYBR dyes)
Sequencing reagents
Nucleic acid stains and dyes
Restriction enzymes and molecular biology reagents
Point-of-Care Testing (POCT) Waste:
Glucose meter quality control solutions
Blood gas analyzer waste
Portable coagulation device reagents
Rapid diagnostic test waste
Radiology and Imaging Waste
Medical imaging departments generate photographic chemistry waste and equipment-related hazardous materials.
X-Ray Processing Chemistry:
Developer solutions containing hydroquinone and phenidone (toxic reducing agents)
Fixer solutions containing silver (precious metal recovery possible), sodium thiosulfate, acetic acid
Spent fixer with high silver content (>5 troy ounces per gallon qualifies for silver recovery)
Rinse water from film processing
Note: Digital radiography has largely replaced film-based X-rays, significantly reducing chemistry waste. However, many facilities still operate film processors for certain applications (mammography, dental radiography, veterinary medicine).
Silver Recovery Opportunities: Fixer solutions contain recoverable silver that can be:
Electrolytically recovered on-site with silver recovery units
Chemically precipitated with recovery chemicals
Sent for off-site silver reclamation (reduces disposal costs, generates revenue)
Other Imaging Department Waste:
Contrast media (iodinated compounds, gadolinium-based agents)
Nuclear medicine waste (radioactive materials under separate NRC/state regulations)
MRI equipment maintenance fluids (helium, cryogenic fluids)
CT scanner maintenance chemicals
Ultrasound equipment cleaners
Mercury-Containing Medical Waste
Mercury devices are being phased out but remain in use at some healthcare facilities, requiring specialized disposal.
Mercury-containing medical equipment:
Mercury thermometers (fever thermometers, laboratory thermometers)
Mercury sphygmomanometers (blood pressure devices)
Gastrointestinal tubes containing mercury (Cantor tubes, Miller-Abbott tubes)
Esophageal dilators with mercury weights
Dental amalgam (separate dental waste stream)
Laboratory equipment (mercury switches in older equipment)
Broken mercury devices creating metallic mercury contamination
Mercury waste management:
Intact mercury devices should be recycled through universal waste programs
Broken devices creating mercury spills require specialized cleanup
Dental amalgam waste subject to EPA Effluent Limitation Guidelines
Many states have banned mercury thermometers and sphygmomanometers
Replacement with digital alternatives recommended
Pharmaceutical Wastewater and Contaminated Materials
Healthcare facilities generate wastewater and materials contaminated with pharmaceutical residues.
Wastewater Streams:
Toilet and sink waste from patient care areas (contains excreted pharmaceuticals)
Sink waste from medication preparation areas
Contaminated rinse water from equipment cleaning
Spill cleanup wash water
HVAC condensate from cleanrooms and compounding areas
Steam sterilizer condensate
Most pharmaceutical wastewater:
Not regulated as RCRA hazardous waste if disposed to sanitary sewer
Subject to local pretreatment requirements
Some facilities implement pharmaceutical waste minimization programs
Emerging concern regarding pharmaceutical water contamination
Contaminated Materials Requiring Disposal:
Personal protective equipment (PPE) from chemotherapy handling (gowns, gloves, shoe covers)
Empty IV bags that contained hazardous pharmaceuticals
Vials and syringes from hazardous drug administration
Tubing and administration sets
Contaminated linens and textiles
Spill cleanup materials (absorbents, wipes, mops)
HEPA filters from compounding hoods
Glove box and biological safety cabinet HEPA filters
Healthcare Facility Types We Serve
Hospitals and Medical Centers
Acute care hospitals generate the most diverse pharmaceutical and medical waste streams of any healthcare facility type.
Major hospital systems we serve:
Northeast:
Massachusetts General Hospital (Boston MA) - Academic medical center, comprehensive services
Brigham and Women's Hospital (Boston MA) - Harvard teaching hospital
Yale New Haven Hospital (New Haven CT) - Academic medical center
NewYork-Presbyterian Hospital (New York NY) - Columbia and Cornell affiliated
Mount Sinai Health System (New York NY) - Multiple facilities
NYU Langone Health (New York NY) - Academic medical center
Hospital of the University of Pennsylvania (Philadelphia PA)
Johns Hopkins Hospital (Baltimore MD) - Renowned research hospital
UPMC (Pittsburgh PA) - Large integrated health system
Southeast:
Duke University Hospital (Durham NC) - Academic medical center
Emory University Hospital (Atlanta GA)
Vanderbilt University Medical Center (Nashville TN)
University of Virginia Medical Center (Charlottesville VA)
Tampa General Hospital (Tampa FL)
Jackson Memorial Hospital (Miami FL) - Large public hospital
Shands Hospital at University of Florida (Gainesville FL)
Midwest:
Cleveland Clinic (Cleveland OH) - World-renowned cardiac care
Mayo Clinic (Rochester MN) - Integrated academic medical center
University of Chicago Medical Center (Chicago IL)
Northwestern Memorial Hospital (Chicago IL)
Rush University Medical Center (Chicago IL)
University of Michigan Health (Ann Arbor MI)
Barnes-Jewish Hospital (St. Louis MO) - Washington University affiliated
Ohio State University Wexner Medical Center (Columbus OH)
West:
UCSF Medical Center (San Francisco CA)
Stanford Health Care (Palo Alto CA)
UCLA Medical Center (Los Angeles CA)
Cedars-Sinai Medical Center (Los Angeles CA)
University of Washington Medical Center (Seattle WA)
Oregon Health & Science University (Portland OR)
University of Colorado Hospital (Aurora CO)
Mayo Clinic (Phoenix and Scottsdale AZ)
Hospital waste includes:
Oncology department chemotherapy waste
Operating room pharmaceutical waste and sharps
Emergency department medications and supplies
Pharmacy department expired and unusable medications
Intensive care unit (ICU) pharmaceutical waste
Clinical laboratory chemical waste
Radiology department chemistry (declining with digital)
Patient care area contaminated materials
Outpatient Clinics and Physician Offices
Ambulatory care settings generate smaller quantities but still require compliant disposal.
Clinic types generating pharmaceutical waste:
Oncology and infusion centers: Chemotherapy waste from outpatient cancer treatment
Dialysis centers: Davita, Fresenius, independent centers generate pharmaceutical waste
Surgical centers: Ambulatory surgery centers use anesthetics, controlled substances
Pain management clinics: Controlled substance administration, injection waste
Urgent care centers: Medications, contrast agents, procedural waste
Specialty clinics: Dermatology (chemical peels, cryotherapy), ophthalmology (diagnostic drops), rheumatology (injectable biologics)
Primary care offices: Expired vaccine refrigerators, sample medications, office-use pharmaceuticals
Long-Term Care and Nursing Homes
Skilled nursing facilities, assisted living, and memory care facilities accumulate significant quantities of patient-specific medications.
Long-term care waste challenges:
Patient-specific medications discontinued when residents pass away, transfer, or change prescriptions
Blister-packed and unit-dose medications difficult to return to pharmacy
Controlled substance waste requires DEA compliance and witness destruction
Medication cart cleanouts during facility transitions
Hospice patient medication disposal after death (often includes substantial opioid quantities)
Major long-term care operators:
Brookdale Senior Living - Large assisted living and skilled nursing operator
Genesis HealthCare - Skilled nursing and rehabilitation
Encompass Health - Rehabilitation hospitals
Kindred Healthcare - Long-term acute care hospitals
Life Care Centers of America
Five Star Senior Living
Retail and Community Pharmacies
Pharmacies handle returned medications, expirations, damaged inventory, and recalled drugs.
Major pharmacy chains:
CVS Pharmacy - Thousands of locations nationwide
Walgreens/Duane Reade - Major retail pharmacy chain
Rite Aid - Pharmacy chain in multiple states
Walmart Pharmacy - In-store pharmacy operations
Kroger Pharmacy - Grocery-based pharmacies
Safeway/Albertsons Pharmacy - Supermarket pharmacies
Sam's Club/Costco Pharmacy - Wholesale club pharmacies
Independent pharmacies - Locally-owned community pharmacies
Pharmacy waste streams:
Expired over-the-counter and prescription medications
Damaged products from shipping or storage
Discontinued products no longer carried
Recalled medications from manufacturer or FDA recalls
Returns from patients (now accepted under certain DEA regulations)
Controlled substances requiring DEA Form 41 compliance
Cytotoxic handling waste from chemotherapy compounding
Compounding Pharmacies
Specialized pharmacies preparing customized medications generate unique wastes.
Compounding waste includes:
Bulk API powders and raw materials
Compounding cleaning waste
Failed preparations not meeting quality standards
Expired compounded preparations
Sterile compounding room HEPA filter waste
Cytotoxic waste from chemotherapy compounding operations
Major compounding pharmacy types:
Sterile compounding: IV medications, injections, ophthalmic preparations
Non-sterile compounding: Topical preparations, oral dosage forms
Specialty compounding: Hormone replacement therapy, pain management, veterinary
503B Outsourcing facilities: Large-scale sterile compounding with enhanced FDA oversight
Veterinary Clinics and Animal Hospitals
Veterinary medicine generates pharmaceutical waste similar to human healthcare.
Veterinary pharmaceutical waste:
Expired animal medications
Controlled substances (ketamine, buprenorphine, butorphanol, tramadol, phenobarbital)
Chemotherapy drugs for animal cancer treatment
Euthanasia solutions (pentobarbital - Schedule II controlled substance)
Parasiticides and pesticides
Anesthetic waste gases
Laboratory chemicals
Diagnostic reagents
Major veterinary hospital chains:
VCA Animal Hospitals (owned by Mars Petcare) - Hundreds of locations
Banfield Pet Hospital (Mars Petcare) - In-store veterinary clinics at PetSmart
BluePearl Veterinary Partners - Emergency and specialty veterinary hospitals
National Veterinary Associates (NVA) - Multi-state veterinary hospital network
Southern Veterinary Partners (SVP)
Mission Veterinary Partners
Specialty veterinary facilities:
Oncology centers treating animal cancers
Emergency and critical care hospitals
Specialty surgical centers
Equine hospitals and large animal practices
Laboratory animal facilities at research institutions
Home Healthcare and Hospice
Providers delivering care in patient homes face unique waste challenges.
Home healthcare waste:
Discontinued patient medications after death or discharge
Unused hospice comfort kit medications (often include opioids)
Home infusion therapy waste
Diabetic supplies and sharps
Visiting nurse medications and supplies
Palliative care pharmaceutical waste
Major home health and hospice providers:
Amedisys - Home health and hospice services
LHC Group - Home health and hospice provider
Kindred at Home (Gentiva) - Home health, hospice, and personal care
Encompass Health Home Health
BrightSpring Health Services
VITAS Healthcare - Large hospice provider
Chapters Health System
Clinical Research Organizations and Contract Research
CROs conducting clinical trials generate investigational drug waste.
Clinical trial waste:
Unused investigational drug products
Expired clinical trial materials
Failed stability study samples
Placebo materials
Comparator drugs
Returned patient medications from clinical trials
Drug accountability and inventory waste
Major CROs:
IQVIA - Global CRO and healthcare data provider
LabCorp Drug Development - Clinical trial laboratory services
PPD (now part of Thermo Fisher) - Clinical research services
Syneos Health - Biopharmaceutical solutions organization
ICON plc - Global CRO
PRA Health Sciences (now ICON)
Parexel - Clinical research services
WuXi AppTec - Pharma R&D and manufacturing
Pharmaceutical Waste Regulations and Compliance
EPA RCRA Hazardous Waste Regulations
The Resource Conservation and Recovery Act (RCRA) establishes the framework for hazardous waste management including pharmaceutical waste.
Hazardous Pharmaceutical Waste Determination
Pharmaceuticals are hazardous waste if they exhibit a hazardous characteristic or are specifically listed.
Characteristic Hazardous Waste (D-codes):
Ignitability (D001): Flash point <140°F
Alcohol-based medications and tinctures
Aerosols and inhalers (due to propellants)
Hand sanitizers with >24% alcohol
Some compounding solvents
Corrosivity (D002): pH ≤2 or ≥12.5
Strong acids used in compounding
Strong bases and alkaline solutions
Some cleaning and disinfecting agents
Reactivity (D003): Unstable, water-reactive, or potentially explosive
Peroxide-forming chemicals in laboratory settings
Certain chemotherapy agents
Oxidizers and reactive compounds
Toxicity (D004-D043): Contains specific toxic elements or compounds above regulatory levels
Arsenic (D004) - rare in modern pharmaceuticals
Selenium (D010) - some nutritional supplements
Mercury (D009) - preservatives, antiseptics (thimerosal)
Silver (D011) - silver nitrate cauterization sticks
Chromium (D007) - some nutritional supplements
Lead (D008) - rare but possible in older medications
Listed Hazardous Wastes (P and U codes):
P-Listed (Acutely Hazardous):
P001: Warfarin >0.3% (anticoagulant rodenticide formulations)
P042: Epinephrine (adrenaline in pure form)
P075: Nicotine and nicotine salts (pure nicotine, concentrated forms)
P092: Phenylmercuric acetate (preservative, rare in modern use)
P106: Sodium cyanide (extremely rare in pharmaceuticals)
P204: Physostigmine and salts (highly toxic alkaloid)
U-Listed (Toxic):
U010: Mitomycin C (chemotherapy agent)
U058: Cyclophosphamide (chemotherapy agent)
U106: Diethylstilbestrol (DES, rarely used today)
U122: Formaldehyde (tissue fixation, preservatives)
U129: Lindane (neurotoxic pesticide, limited medical use)
U186: 1,3-Pentadiene (rare pharmaceutical ingredient)
U237: Uracil mustard (chemotherapy agent)
U359: 2-Methylaziridine (alkylating agent)
Important Notes on Listed Wastes:
P and U codes apply to UNUSED commercial chemical products only
Empty containers that held P or U listed wastes may still be hazardous
"Empty" has specific regulatory meaning (RCRA empty standards)
Many chemotherapy drugs are P or U listed requiring stringent management
Non-Hazardous Pharmaceutical Waste: Most expired and unwanted medications are NOT RCRA hazardous waste but still require proper disposal to prevent environmental contamination and drug diversion.
Healthcare Generator Categories
Healthcare facilities are classified based on monthly hazardous waste generation.
Very Small Quantity Generators (VSQGs):
Generate <100 kg (220 lbs) per month hazardous waste
Accumulate <1,000 kg on-site at any time
Most small physician offices, clinics, dental practices
Minimal regulatory requirements but must ensure proper disposal
Not required to have EPA ID number (but recommended)
Not required to manifest waste (but best practice)
Must send waste to legitimate disposal facility
Small Quantity Generators (SQGs):
Generate 100-1,000 kg per month hazardous waste
Must obtain EPA ID number
Can accumulate waste for 180 days (270 days if disposal facility >200 miles)
Must manifest hazardous waste shipments
Basic employee training requirements
Must have emergency preparedness procedures
Many medium-sized hospitals, large clinics, surgical centers
Large Quantity Generators (LQGs):
Generate ≥1,000 kg per month hazardous waste OR >1 kg per month acutely hazardous (P-listed) waste
Must obtain EPA ID number
Can accumulate waste maximum 90 days
Must manifest all hazardous waste shipments
Comprehensive employee training programs with annual refreshers
Written contingency plans and emergency procedures
Weekly storage area inspections with documentation
Biennial hazardous waste reporting to EPA
Must have certified personnel and formal training programs
Large hospitals, pharmaceutical manufacturers, major research institutions
Generator Category Impacts:
Determines accumulation time limits
Affects training and documentation requirements
Influences facility inspection frequency by regulators
Impacts insurance and liability considerations
Many facilities implement aggressive waste minimization to maintain SQG status and avoid LQG requirements
DEA Controlled Substance Regulations
The Drug Enforcement Administration regulates controlled substance disposal under the Controlled Substances Act.
DEA Registration and Authorization
Only authorized DEA registrants can handle controlled substance disposal:
Authorized Entities:
Reverse distributors: DEA-registered companies authorized to receive controlled substances for destruction (our company partners with authorized reverse distributors)
Manufacturers: With authorization to destroy returned substances
Retail pharmacies: With proper DEA registration and procedures
Hospitals and practitioners: With DEA registration, can destroy under specific circumstances
Narcotic treatment programs: With special authorization
Law enforcement: Can receive controlled substances from the public
DEA Registration Requirements:
All entities handling controlled substances must maintain current DEA registration
Registration type determines authorized activities
Separate registration required for each physical location
Registration must be renewed every three years
Registration can be suspended or revoked for violations
DEA Form 41 Requirements
Controlled substance destruction requires DEA Form 41 (Registrants' Inventory of Drugs Surrendered).
DEA Form 41 Information Required:
Registrant name and DEA registration number
Complete inventory of drugs being destroyed including:
Drug name (brand and generic)
National Drug Code (NDC) number
Dosage form and strength
Quantity (number of units, not just weight)
Whether controlled or non-controlled
Date of inventory
Two-witness requirement for verification
Signatures of authorized personnel
Method of disposal
Form 41 Process:
Registrant inventories controlled substances for destruction
Two witnesses observe and verify inventory
Form 41 completed with all required information
Substances transferred to reverse distributor OR destroyed on-site with DEA authorization
Completed Form 41 submitted to DEA Field Office
Copy retained by registrant for two years
Perpetual inventory adjusted for disposed substances
Common Form 41 Mistakes to Avoid:
Incomplete drug information (missing NDC, strength, or quantity)
Improper witness signatures
Incorrect DEA registration numbers
Mixing non-controlled substances on Form 41 (list separately)
Not retaining required documentation
Not submitting to correct DEA field office
Controlled Substance Security Requirements
Healthcare facilities must implement security measures for controlled substances.
Security Requirements:
Secure storage: Locked cabinets, safes, or pharmacy vaults for controlled substance waste
Access control: Limited access to authorized personnel only
Surveillance: Many facilities use cameras in areas storing controlled substances
Inventory controls: Perpetual inventory systems tracking all controlled substances
Theft prevention: Physical security measures to prevent diversion
Transportation security: Locked vehicles, direct custody, GPS tracking recommended
Documentation: Complete chain of custody from generation to final destruction
Diversion Prevention:
The opioid crisis has intensified DEA scrutiny of controlled substance handling
Facilities must demonstrate robust controls preventing theft or diversion
Employee screening and background checks for personnel handling controlled substances
Unusual losses must be reported to DEA (Form 106 for thefts and significant losses)
Regular audits of controlled substance inventories
State-Specific Pharmaceutical Waste Regulations
Many states have enacted regulations beyond federal EPA and DEA requirements.
States with Enhanced Pharmaceutical Waste Regulations
California:
Medical Waste Management Act regulates pharmaceutical waste as medical waste in some circumstances
Pharmaceutical waste that is also a hazardous waste subject to both regulations
CalRecycle and DTSC oversight
Universal waste regulations for certain pharmaceuticals
Extended producer responsibility discussions for pharmaceutical waste
Washington:
Dangerous Waste Regulations (WAC 173-303) more stringent than federal RCRA in some aspects
Ecology administers pharmaceutical waste program
State criteria may classify more pharmaceuticals as dangerous waste than federal hazardous
Annual reporting for LQGs rather than biennial
Minnesota:
Hospital and health care facility waste rules
Minnesota Pollution Control Agency (MPCA) oversight
Specific requirements for pharmaceutical waste management plans
Massachusetts:
Department of Environmental Protection (DEP) pharmaceutical waste regulations
Enhanced controls for healthcare facility waste
Universal waste programs for certain pharmaceuticals
New York:
NYSDEC hazardous waste regulations with strict enforcement
No 270-day extension for SQGs (strict 180-day limit)
Annual generator fees
Enhanced pharmaceutical waste requirements
Vermont:
Enhanced regulations for pharmaceutical waste disposal
State program administered by DEC
Specific requirements for healthcare facilities
Other States with Specific Requirements: Many states have additional regulations including Illinois, New Jersey, Pennsylvania, Oregon, and others. We stay current with all state-specific requirements and ensure compliance across all jurisdictions.
State Pharmaceutical Take-Back Programs
Many states have enacted pharmaceutical take-back programs:
Extended Producer Responsibility (EPR) programs requiring manufacturers to fund collection
Safe drug disposal programs operated by state agencies
Authorized collector programs at pharmacies and law enforcement
Mail-back programs for patient medications
These programs typically apply to patient medications, not healthcare facility waste generation. Healthcare facilities must use commercial disposal services for their pharmaceutical waste.
FDA Regulations and Recommendations
The Food and Drug Administration provides guidance on pharmaceutical waste.
FDA Recommendations:
FDA Flush List identifies certain medications recommended for flushing down toilet if no take-back options available (applies to patients, not healthcare facilities)
Most medications should NOT be flushed due to environmental concerns
FDA recommends disposal of most medications in household trash after mixing with unpalatable substances (again, patient guidance not for healthcare facilities)
Healthcare facilities should follow EPA RCRA and DEA requirements, not FDA patient recommendations
FDA Oversight:
Drug recalls may result in large quantities requiring disposal
Expired drugs must be disposed of properly
503B compounding outsourcing facilities under enhanced FDA oversight for waste handling
Our Pharmaceutical Waste Services
Comprehensive Pharmaceutical Waste Management Programs
We provide complete turnkey pharmaceutical waste management for healthcare facilities of all sizes.
Program Components:
Initial waste assessment and facility survey
Waste stream characterization and classification
Regulatory status determination (RCRA, DEA, state requirements)
Container provision (chemotherapy, pharmaceutical, sharps, controlled substance)
Labeling and compliance materials
Employee training programs
Scheduled pickup services
Controlled substance destruction with DEA Form 41 compliance
Manifest and documentation management
Certificates of destruction
Regulatory compliance support
Waste minimization consulting
Chemotherapy Waste Disposal
Specialized handling for cytotoxic pharmaceutical waste.
Chemotherapy Waste Services:
Yellow chemotherapy waste containers sized appropriately for generation rates
Trace chemotherapy waste containers for materials with residual contamination
Bulk chemotherapy waste for large facilities
Pickup scheduling coordinated with facility needs (weekly, bi-weekly, monthly)
Incineration disposal ensuring complete destruction
Chemotherapy spill cleanup and waste management
Training for nursing staff and pharmacy on chemotherapy waste segregation
Compliance with state-specific chemotherapy waste requirements
Facilities we serve:
Oncology practices and infusion centers
Hospital oncology departments
Cancer treatment centers
Compounding pharmacies preparing chemotherapy
Research institutions studying chemotherapy agents
Veterinary oncology practices
Pharmaceutical Waste Disposal
Non-chemotherapy pharmaceutical waste management.
Services Include:
Pharmaceutical waste containers (various sizes)
Expired medication disposal
Recalled drug disposal
Damaged medication disposal
Patient return medication disposal (where allowed)
Investigational drug disposal for clinical trials
Vaccine waste disposal
Biological product waste disposal
Proper Segregation: We help facilities segregate:
RCRA hazardous pharmaceutical waste (requiring manifesting and RCRA disposal)
Non-hazardous pharmaceutical waste (majority of medications)
Controlled substances (requiring DEA compliance)
Chemotherapy waste (requiring incineration)
This segregation reduces costs while maintaining compliance
Controlled Substance Disposal (DEA Compliance)
Complete controlled substance disposal with DEA Form 41 compliance.
Controlled Substance Services:
Authorized reverse distribution partnerships
DEA Form 41 preparation and submission
Two-witness inventory and verification
Secure transportation with chain of custody
Witnessed destruction (on-site or at authorized facility)
Documentation for DEA compliance
Perpetual inventory reconciliation support
Assistance with DEA reporting requirements
Process:
Facility inventories controlled substances for disposal
We schedule service and provide DEA Form 41 assistance
Our authorized personnel witness inventory with facility staff (two-witness requirement)
Controlled substances secured in locked transport
Substances transported to authorized reverse distributor
Destruction witnessed and documented
Completed Form 41 submitted to DEA
Certificate of destruction provided to facility
Facility adjusts perpetual inventory
Especially Important For:
Hospital pharmacies with extensive controlled substance inventories
Long-term care facilities with patient-specific controlled substance waste
Hospice programs with unused opioid inventories after patient deaths
Retail pharmacies with expired or returned controlled substances
Veterinary practices with animal controlled substances
Pain management clinics
Laboratory Chemical Waste Disposal
Hospital and clinical laboratory chemical waste management.
Laboratory Waste Services:
Lab pack services for diverse chemical inventories
Formaldehyde waste disposal (pathology and histology labs)
Xylene and alcohol disposal (tissue processing)
Reagent and quality control material disposal
Heavy metal standards disposal
Expired chemical disposal
Broken thermometer mercury cleanup
Spill cleanup and emergency response
Laboratory Types:
Clinical chemistry laboratories
Hematology and coagulation labs
Microbiology laboratories
Pathology and histology labs
Blood bank laboratories
Molecular diagnostics labs
Cytogenetics and cytology labs
Flow cytometry labs
Research laboratories
Radiology and X-Ray Chemistry Disposal
Management of photographic processing waste from medical imaging.
X-Ray Chemistry Services:
Developer solution disposal
Fixer solution disposal with silver recovery options
Silver recovery programs generating revenue from spent fixer
Dental x-ray chemistry disposal
Veterinary radiology waste disposal
Mammography chemistry disposal
Silver Recovery Benefits:
Reduces disposal costs significantly
Generates revenue from recovered silver
Environmental benefits from reclaiming precious metals
Available for facilities still using film-based radiography
Note: Digital radiography has largely replaced film in most facilities, but many dental offices, veterinary clinics, and some specialized applications continue using film requiring chemistry disposal.
Pharmaceutical Waste Containerization
Appropriate containers for all pharmaceutical waste types.
Container Options:
Chemotherapy Waste Containers:
2-gallon, 3-gallon, 5-gallon, and 8-gallon sizes
Yellow color-coded for visual identification
Leak-proof construction meeting DOT specifications
Clear labeling "Chemotherapy Waste - For Incineration Only"
Available with hinged lids for easy access
Pharmaceutical Waste Containers:
2-gallon through 20-gallon sizes
Blue or white containers (non-chemotherapy pharmaceutical waste)
Designed for solid dosage forms and liquid medications
RCRA-compliant labeling
Controlled Substance Containers:
Lockable containers for secure controlled substance waste storage
Tamper-evident seals
Designed to meet DEA security requirements
Various sizes for different generation rates
Sharps Containers:
Puncture-resistant construction
Multiple sizes from small (1-quart) to large (18-gallon)
For needles, syringes, and other sharps
Available with chemotherapy markings for cytotoxic sharps
Specialty Containers:
Mercury waste containers for thermometers and sphygmomanometers
Amalgam separators for dental offices
Aerosol can puncturing devices (where allowed)
Spill kit containers
Scheduled Pickup Services
Regular, predictable service for ongoing waste generation.
Pickup Frequency Options:
Weekly service for high-volume generators
Bi-weekly service for moderate volumes
Monthly service for typical facilities
Quarterly service for low-volume generators
Custom schedules matching facility needs
Service Features:
Consistent schedule and driver assignments
Container exchange (pickup full, deliver empty)
Manifesting and documentation
Certificates of destruction
Compliance verification
Proactive compliance alerts (approaching accumulation time limits)
Ideal For:
Hospital pharmacies and patient care areas
Outpatient infusion centers
Large physician practices
Long-term care facilities
Veterinary hospitals
Compounding pharmacies
On-Demand and Emergency Services
Flexible service for sporadic needs or urgent situations.
On-Demand Pickup:
Call for pickup when waste accumulates
No long-term service contracts required
Pay-per-pickup pricing
Ideal for facilities with irregular waste generation
Emergency room or urgent care overflow situations
Emergency Response Services:
24/7 availability for urgent needs
Spill cleanup and emergency waste removal
Regulatory inspection support (when regulators identify issues requiring immediate correction)
Facility closure or transition assistance
Recalled medication removal
Expired vaccine refrigerator cleanouts
Disaster response (facility floods, fires, or other emergencies creating immediate waste disposal needs)
Waste Characterization and Consulting
Expert assistance with waste identification and regulatory determination.
Characterization Services:
Waste stream evaluation and EPA waste code determination
RCRA hazardous waste classification
Process knowledge documentation
Analytical testing coordination (when required)
Generator category determination
Waste minimization assessments
Consulting Services:
Regulatory compliance audits
Waste management program development
Written waste management plans
Employee training programs
Standard operating procedure (SOP) development
Best practice recommendations
Cost reduction strategies
Training and Education
Comprehensive training for healthcare facility staff.
Training Topics:
Pharmaceutical waste identification and segregation
RCRA hazardous waste regulations for healthcare
DEA controlled substance waste regulations
Container selection and proper labeling
Accumulation time tracking
Spill response procedures
Safety and personal protective equipment
Facility-specific procedures and SOPs
Training Formats:
On-site group training sessions
Department-specific training (pharmacy, nursing, laboratory)
Online training modules
Training materials and reference guides
Annual refresher training
New employee orientation materials
Documentation:
Training attendance records
Training certificates
Training materials and presentations
Competency verification
Pharmaceutical Waste Disposal Best Practices
Waste Segregation at Point of Generation
Proper segregation is critical for cost control and compliance.
Segregation Principles:
Separate chemotherapy waste from other pharmaceutical waste:
Chemotherapy requires incineration (expensive)
Non-chemotherapy pharmaceutical waste has less expensive disposal options
Mixing increases costs unnecessarily
Clear signage and color-coded containers prevent cross-contamination
Separate hazardous from non-hazardous pharmaceutical waste:
Most expired medications are NOT RCRA hazardous
RCRA hazardous waste requires manifesting and special disposal
Non-hazardous pharmaceutical waste can be disposed more economically
Understanding P and U listed wastes prevents unnecessary hazardous waste classification
Separate controlled substances:
DEA regulations require separate tracking and documentation
Controlled substance containers should be lockable
Keep separate from non-controlled pharmaceutical waste
Maintain perpetual inventory for controlled substance waste
Benefits of Proper Segregation:
Reduced disposal costs (30-50% savings possible)
Simplified regulatory compliance
Easier inventory and tracking
Reduced liability and risk
Better waste minimization data
Container Management and Labeling
Proper container practices ensure safety and compliance.
Container Selection:
Use appropriate container type and size for waste stream
Ensure compatibility (containers must be compatible with waste contents)
DOT-specification containers for transportation
Leak-proof construction preventing spills
Container Placement:
Locate containers at point of waste generation (medication rooms, pharmacy, chemotherapy preparation areas)
Secure areas preventing unauthorized access
Away from patient care areas when possible
Clearly visible and easily accessible to authorized staff
Protected from weather and temperature extremes
Labeling Requirements:
"Hazardous Waste" label for RCRA waste
Waste contents description
Accumulation start date (critical for accumulation time limits)
Generator name and address
EPA ID number
Hazard class and identification number for transportation
Container Management:
Keep containers closed except when adding waste
Inspect containers regularly for leaks or damage
Replace damaged containers immediately
Don't overfill (leave adequate headspace)
Use absorbent material in liquid pharmaceutical waste containers
Secure lids after each use
Accumulation Time Tracking
Diligent tracking prevents violations.
Accumulation Time Limits:
LQGs: 90 days maximum
SQGs: 180 days maximum (or 270 days if >200 miles to disposal facility)
VSQGs: No federal time limit but recommended to dispose regularly
Tracking Systems:
Mark accumulation start date on each container when first adding waste
Use facility tracking systems (logbooks, spreadsheets, or software)
Set reminders before accumulation limits approach
Schedule pickups allowing adequate time before limits
Consider weekly or monthly accumulation date audits
Common Problems:
Unmarked containers (unknown accumulation date)
Faded or illegible dates
Incorrect dates (accumulation starts when FIRST adding waste, not when container is full)
Exceeded time limits due to forgotten containers
Lack of centralized tracking
Best Practices:
Use permanent markers on container labels
Photograph containers and dates periodically
Implement centralized tracking system
Assign responsibility for accumulation date monitoring
Schedule pickups well before limits to allow for scheduling flexibility
Employee Training Programs
Well-trained staff are essential for compliance.
Training Requirements:
Annual training for employees handling hazardous waste
Initial training before job assignment
Training within six months for new employees (LQG requirement)
Documentation of training dates, topics, and attendees
Essential Training Content:
Waste identification and characterization
Segregation procedures
Container selection and labeling
Accumulation time requirements
Spill response and emergency procedures
Personal protective equipment (PPE)
Facility-specific procedures and SOPs
Regulatory overview (RCRA, DEA as applicable)
Training Methods:
Group classroom sessions
Department-specific training
Hands-on demonstrations
Computer-based training modules
Annual refresher training
Just-in-time reminders and reference materials
Documentation Best Practices:
Training sign-in sheets with dates and employee signatures
Training materials and handouts
Training certificates
Competency assessments
Training records maintained for minimum three years after employee separation
Readily accessible for regulatory inspections
Spill Response and Emergency Procedures
Preparedness prevents incidents from becoming emergencies.
Spill Response Kits:
Absorbent materials (pads, booms, pillows)
Personal protective equipment (gloves, goggles, gowns, respirators if needed)
Neutralizing agents (for acid/base spills where appropriate)
Disposal containers and bags
Spill response procedures and emergency contacts
Spill Response Procedures:
Ensure personal safety first
Alert nearby personnel
Contain spill to prevent spreading
Evacuate area if hazardous vapors or large spills
Notify appropriate personnel (safety officer, environmental health and safety)
Clean up spill using appropriate PPE and methods
Place waste in proper disposal containers
Decontaminate affected areas
Document incident
Report if required by regulations
Emergency Contacts:
Facility safety officer
Environmental health and safety department
Hazardous waste disposal company (us!) for assistance
Local fire department or hazmat team for large or dangerous spills
State environmental agency for reportable quantity releases
National Response Center (1-800-424-8802) for significant releases
Chemotherapy Spill Considerations:
Chemotherapy spills require specialized cleanup procedures
Personnel should have specific chemotherapy spill training
Chemotherapy spill kits should be available in preparation and administration areas
Two people should perform cleanup when possible
Complete PPE required (gowns, double gloves, face protection, shoe covers)
All materials must be disposed as chemotherapy waste
Waste Minimization Strategies
Reducing pharmaceutical waste saves money and protects the environment.
Inventory Management:
Implement first-in, first-out (FIFO) inventory rotation
Monitor expiration dates closely
Order quantities matching actual usage to prevent overstocking
Centralized purchasing to reduce duplicate expired stock
Computerized inventory systems tracking expirations
Clinical Practices:
Patient-specific dosing and unit dose systems reduce excess medications
Review physician prescribing patterns to reduce discontinued medications
Medication reconciliation at transitions of care
Patient education on medication adherence
Automatic stop orders for certain medications
Process Improvements:
Evaluate batch sizes for compounded preparations
Implement just-in-time delivery for short-dated products
Return programs with suppliers and distributors (where allowed)
Donation programs for unexpired usable medications (must meet legal requirements)
Substitution of less hazardous alternatives where clinically appropriate
Cost Benefits:
Reduced purchasing costs (buy less that expires)
Lower disposal costs (less waste generated)
Labor savings (less time managing waste)
Regulatory benefits (potentially lower generator category)
Documentation and Record Keeping
Meticulous records demonstrate compliance and protect from liability.
Required Documentation:
Manifests:
Signed hazardous waste manifests for all RCRA waste shipments
Retain for minimum three years (longer recommended)
File systematically for easy retrieval
Verify receipt of signed copy from disposal facility within 35-45 days
Exception reporting if manifests not returned
DEA Form 41:
Completed forms for all controlled substance disposals
Copy to DEA Field Office
Retain copy for two years minimum
Attach to perpetual inventory documentation
Certificates of Destruction:
Obtain from disposal company for all waste disposed
Verify waste descriptions match manifests
File with corresponding manifests
Provide proof of disposal for audits
Training Records:
Employee training dates and topics
Training materials
Attendance rosters with signatures
Competency assessments
Maintain for three years after employee separation
Inspection Logs:
Weekly inspection records for storage areas
Document date, inspector name, findings
Corrective actions for deficiencies
Container condition, labeling, dates
Readily accessible for regulatory inspections
Waste Characterization:
Process knowledge documentation
Analytical results if testing performed
EPA waste code determinations
Generator knowledge supporting classifications
Perpetual Inventory (Controlled Substances):
All controlled substance receipts and administrations
Controlled substance waste generations
Running balance for each controlled substance
Reconciliation documentation
Best Practices:
Centralized filing system
Digital scanning and backup
Retention schedule following regulations (minimum) and best practices (longer)
Readily accessible for inspections and audits
Periodic review to ensure completeness
Pharmaceutical Waste Disposal Costs
Understanding cost factors helps facilities budget appropriately and identify savings opportunities.
Cost Factors
Waste Type and Classification:
Chemotherapy waste (most expensive): Requires incineration disposal
RCRA hazardous pharmaceutical waste: Requires manifesting and hazardous waste disposal
Controlled substances: Requires DEA compliance and witness destruction
Non-hazardous pharmaceutical waste: Less expensive disposal options
Proper segregation significantly reduces costs
Waste Quantity:
Volume discounts for larger quantities
Per-pound or per-container pricing
Minimum charges may apply for very small quantities
Annual agreements for predictable high volumes
Service Frequency:
Scheduled regular service typically more cost-effective than on-demand
Frequency affects per-pickup costs
Balancing service frequency with accumulation time limits
Geographic Location:
Transportation distances to disposal facilities
Certain regions have higher disposal costs
Rural areas may have higher transportation costs
Proximity to permitted incinerators affects chemotherapy waste costs
Container Types and Sizes:
Container purchase or rental costs
Specialized containers (lockable, chemotherapy-specific) cost more
Larger containers may offer better per-gallon costs
Container exchange programs simplify budgeting
Regulatory Compliance Services:
Training programs
Waste characterization services
Emergency response capabilities
Documentation and manifest management
DEA Form 41 assistance
Consulting services
Typical Cost Ranges
Chemotherapy Waste Disposal:
Small containers (2-3 gallon): $150-$300 per container
Medium containers (5-8 gallon): $300-$600 per container
Per-pound pricing: $3-$8 per pound
Annual costs for typical infusion center: $3,000-$15,000
Large hospital oncology department: $20,000-$100,000+ annually
Pharmaceutical Waste (Non-Chemotherapy, Non-Hazardous):
Per-pound pricing: $1-$4 per pound
Per-container: $100-$400 depending on size
Bulk disposal for large cleanouts: $500-$3,000+ per pickup
Annual costs for medium hospital: $5,000-$30,000
Controlled Substance Disposal:
DEA-compliant disposal with Form 41: $200-$600 per pickup
Based on complexity and quantity
Witness destruction requirements increase costs
On-site destruction options may reduce costs for large facilities
Laboratory Chemical Waste (Lab Packs):
Per-drum pricing: $250-$800 per 55-gallon drum
Depends on chemical types and hazard profiles
Formaldehyde disposal: $3-$10 per gallon
Xylene disposal: $3-$8 per gallon
X-Ray Chemistry Disposal:
Developer: $2-$6 per gallon
Fixer: $1-$4 per gallon (LESS when silver recovery program in place)
Silver recovery can generate revenue offsetting disposal costs
Emergency Response Services:
Emergency spill cleanup: $500-$5,000+ depending on scope
Emergency same-day or next-day pickup: Premium charges $200-$500 above standard rates
After-hours service: Additional charges apply
Training and Consulting:
On-site training sessions: $500-$2,000 per session
Compliance audits: $1,000-$5,000 depending on facility size
Waste characterization: $500-$3,000 depending on complexity
Volume Discounts:
Annual service agreements offer 10-30% cost savings
Larger quantities receive better per-unit pricing
Multi-facility organizations can negotiate enterprise pricing
Cost Reduction Strategies
Optimize Waste Segregation:
Separate chemotherapy from non-chemotherapy pharmaceutical waste (can save 30-50% on non-chemo waste)
Separate RCRA hazardous from non-hazardous
Don't dispose of non-controlled substances as controlled substances
Proper segregation is the single most effective cost control strategy
Implement Waste Minimization:
Reduce purchasing of excessive quantities
Improve inventory rotation and expiration date management
Implement unit dose and patient-specific dosing
Clinical practice changes reducing waste generation
Optimize Service Frequency:
Balance accumulation time limits with service frequency
Consolidate pickups when possible
Avoid emergency or rush pickups through proper planning
Schedule regular service matching waste generation rates
Container Management:
Right-size containers for waste streams (don't use oversized containers)
Container exchange programs reduce handling and storage costs
Maximize fill levels without overfilling
Use appropriate container types (don't use expensive chemotherapy containers for non-chemo waste)
Silver Recovery Programs:
Implement silver recovery for x-ray fixer solutions
Can generate revenue of $100-$1,000+ annually depending on volume
Reduces fixer disposal costs significantly
Environmental benefit from precious metal reclamation
Annual Service Agreements:
Negotiate fixed pricing for predictable budgeting
Volume commitments receive better pricing
Multi-year agreements may offer additional savings
Quarterly business reviews identifying further savings opportunities
Staff Training:
Well-trained staff make fewer costly mistakes
Reduce contamination and mixing of waste streams
Prevent accumulation time violations
Fewer emergency situations requiring premium services
Common Pharmaceutical Waste Questions
Q: Are all expired medications hazardous waste?
A: No. Most expired medications are NOT RCRA hazardous waste. Only medications that exhibit hazardous characteristics (ignitability, corrosivity, reactivity, toxicity) or are specifically P or U listed wastes are RCRA hazardous. However, ALL pharmaceutical waste (hazardous and non-hazardous) requires proper disposal - never down drains or in regular trash. Proper segregation between hazardous and non-hazardous pharmaceutical waste significantly reduces disposal costs.
Q: What's the difference between chemotherapy waste and other pharmaceutical waste?
A: Chemotherapy waste contains cytotoxic drugs (antineoplastic agents) that are carcinogenic, mutagenic, and/or teratogenic. Due to these hazardous properties, chemotherapy waste requires incineration disposal which is more expensive than landfill disposal. Chemotherapy waste includes IV bags, vials, syringes, tubing, and PPE contaminated during chemotherapy handling. Items with only trace amounts of chemotherapy drugs may qualify as "trace chemotherapy waste" with less stringent requirements. Proper segregation of chemotherapy waste from other pharmaceutical waste is critical for cost control.
Q: How do I know if a medication is a P or U listed waste?
A: The EPA maintains lists of P and U waste codes for specific commercial chemical products. P listed wastes are acutely hazardous, while U listed are toxic. Common pharmaceutical P and U listed wastes include warfarin (P001), cyclophosphamide (U058), mitomycin C (U010), physostigmine (P204), nicotine (P075), and several other specific drugs. Importantly, P and U codes apply only to UNUSED commercial chemical products, not to patient-administered medications or empty containers. We can help identify whether your medications are P or U listed and determine proper waste codes.
Q: What are the DEA requirements for disposing of controlled substances?
A: DEA requires specific procedures for controlled substance disposal:
Only authorized DEA registrants can handle controlled substances for destruction
DEA Form 41 must be completed for all controlled substance disposals
Two witnesses must verify the inventory of controlled substances being destroyed
Form 41 must be submitted to the DEA Field Office
Registrant must maintain copy for two years
Perpetual inventory must be adjusted for disposed substances
Secure storage and transportation with chain of custody documentation
We provide DEA-compliant controlled substance disposal services, including Form 41 assistance, witnessed destruction, and complete documentation.
Q: How long can we store pharmaceutical waste before disposal?
A: Storage time limits depend on your generator category:
Large Quantity Generators (LQGs): Maximum 90 days
Small Quantity Generators (SQGs): Maximum 180 days, or 270 days if disposal facility is more than 200 miles away
Very Small Quantity Generators (VSQGs): No federal time limit, but accumulation shouldn't exceed 1,000 kg on-site
The accumulation "clock" starts when you FIRST add waste to a container, not when the container is full. Exceeding accumulation time limits is a common violation. We help facilities track accumulation dates and schedule pickups ensuring compliance.
Q: Can we dispose of pharmaceutical waste down the sink or toilet?
A: Generally NO. Flushing pharmaceuticals can contaminate water supplies and harm aquatic ecosystems. The FDA maintains a small "Flush List" of specific medications recommended for flushing (primarily to prevent accidental ingestion or diversion), but this applies to patient disposal, not healthcare facility waste. Healthcare facilities must follow EPA RCRA and DEA regulations requiring proper waste disposal through authorized companies. Never flush pharmaceutical waste unless specifically advised for certain patient safety scenarios.
Q: What should we do if we exceed our accumulation time limits?
A: Contact us immediately for emergency pickup service. Document the situation including:
Date accumulation limit was exceeded
Reason for the violation
Corrective actions taken
Steps to prevent recurrence
Report the violation to your state environmental agency as required. Many states offer compliance assistance programs for self-disclosed violations. Implement procedures preventing future violations including:
Better accumulation date tracking systems
Earlier pickup scheduling allowing flexibility
Staff training on accumulation time requirements
Automated reminders before limits approach
Q: Do we need an EPA ID number?
A: It depends on your generator category:
Large Quantity Generators and Small Quantity Generators: YES, EPA ID number required
Very Small Quantity Generators: NOT required but recommended
To obtain an EPA ID number, contact your state environmental agency or use EPA's online system. The process typically takes 2-4 weeks. You'll need your EPA ID number for hazardous waste manifesting and reporting.
Q: What's the difference between "empty" and "RCRA empty" for pharmaceutical containers?
A: RCRA defines specific "empty" standards for containers:
For containers ≤110 gallons: All waste removed by normal means (pouring, pumping, etc.), and no more than 3% by weight remains (1 inch or less residue)
For containers >110 gallons: All waste removed and no more than 0.3 inches residue
For acute hazardous (P-listed) waste: Containers must be triple-rinsed or cleaned by equivalent method
"RCRA empty" containers are no longer hazardous waste and can be discarded as regular trash or recycling. Non-RCRA empty containers must be managed as hazardous waste if they contained hazardous materials.
Q: How do we handle pharmaceutical spills?
A: Follow your facility's spill response procedures:
Ensure personal safety - use appropriate PPE
Contain spill to prevent spreading
Alert nearby personnel and evacuate if needed
Clean up using absorbent materials and appropriate methods
Place cleanup materials in proper waste containers
Decontaminate affected surfaces
Document the incident
Report if required by facility policy or regulations
For chemotherapy spills, use specialized chemotherapy spill kits with enhanced PPE and follow cytotoxic drug spill procedures. We can provide emergency spill cleanup assistance for large or complex spills.
Q: Can unused medications be donated to other facilities or patients?
A: Very limited circumstances allow medication donation:
Some states permit donation of unopened, unexpired medications to charitable clinics or developing countries
Strict requirements for handling, storage, and distribution apply
Most patient-specific medications cannot be donated
Opened or partially used medications generally cannot be donated
Controlled substances have additional restrictions
Most unused pharmaceutical waste cannot be donated and requires proper disposal. Check state-specific laws and facility policies before attempting donation.
Q: What training do our employees need for pharmaceutical waste handling?
A: Training requirements depend on generator category and roles:
All employees handling hazardous pharmaceutical waste need training on:
Waste identification and characterization
Proper segregation procedures
Container selection and labeling
Accumulation time requirements
Spill response and emergency procedures
Personal protective equipment
Facility-specific SOPs
Large Quantity Generators must provide:
Initial training before job assignment (or within 6 months)
Annual refresher training
Documentation of training dates, topics, and attendees
Training records maintained for three years after employee separation
Small Quantity Generators and Very Small Quantity Generators should provide:
Initial and periodic training as needed
Documentation recommended even if not required
We provide customized training programs for healthcare facilities of all sizes.
Q: How do we manage pharmaceutical waste during a facility closure or relocation?
A: Contact us for facility closure waste management services:
Complete inventory of all pharmaceutical waste
Expedited disposal coordinating with closure timeline
Cleanout of pharmacy departments, medication rooms, and storage areas
Controlled substance disposal with DEA Form 41 compliance
Laboratory chemical disposal
Equipment decontamination assistance
Documentation for facility closure records
Plan closures well in advance allowing time for proper waste characterization and disposal. Emergency/rush closures incur premium charges but we can accommodate urgent timelines.
Q: What happens to pharmaceutical waste after you pick it up?
A: Pharmaceutical waste disposal pathways depend on waste type:
Chemotherapy waste: Transported to EPA-permitted hazardous waste incinerator for complete thermal destruction at high temperatures (typically >1800°F), ensuring cytotoxic drugs are completely destroyed.
RCRA hazardous pharmaceutical waste: Transported to permitted treatment, storage, and disposal facilities for incineration, fuel blending, chemical treatment, or secure landfill disposal after treatment meeting land disposal restrictions.
Non-hazardous pharmaceutical waste: Transported to permitted waste-to-energy facilities, incinerators, or specially permitted landfills accepting pharmaceutical waste. Some facilities use treatment technologies rendering drugs non-retrievable before disposal.
Controlled substances: Transferred to DEA-authorized reverse distributors who destroy substances under DEA oversight, with destruction witnessed and documented.
We provide certificates of destruction documenting final disposal for all waste, including disposal facility name, disposal method, and completion date.
Q: Are there recycling options for pharmaceutical waste?
A: Limited pharmaceutical waste recycling opportunities exist:
Silver recovery from X-ray fixer: Economically valuable and widely practiced. Silver can be electrolytically recovered, chemically precipitated, or sent to silver reclaimers generating revenue offsetting disposal costs.
Pharmaceutical packaging: Outer packaging (boxes, bottles, etc.) may be recyclable if not contaminated. Contaminated packaging requires disposal as pharmaceutical waste.
Investigational drugs: Some clinical trial medications can be returned to sponsors for evaluation rather than disposal.
Donation programs: Very limited opportunities for unopened, unexpired medications to charitable organizations (state-specific regulations apply).
Most pharmaceutical waste cannot be recycled due to contamination, regulatory restrictions, and lack of reclamation value. Proper disposal is required for the vast majority of pharmaceutical waste.
Getting Started with Pharmaceutical Waste Services
What to Have Ready
When contacting us for pharmaceutical waste disposal services, having the following information helps us provide accurate quotes and appropriate service recommendations:
Facility Information:
Facility type (hospital, clinic, pharmacy, long-term care, etc.)
Number of beds or patient volume
Physical address and service location
Current generator category (if known) or estimated monthly waste quantities
Waste Types and Quantities:
Chemotherapy waste (estimated monthly volume)
General pharmaceutical waste (estimated monthly volume)
Controlled substances (yes/no and approximate quantities)
Laboratory chemical waste (types and quantities)
X-ray chemistry waste (if applicable)
Specific P or U listed wastes (if known)
Current Waste Management:
Existing disposal arrangements (if any)
Current challenges or pain points
Compliance concerns
Accumulation time issues
Service Preferences:
Desired service frequency (weekly, monthly, on-demand)
Container needs (sizes and types)
Special requirements (after-hours pickup, witnessed destruction, training)
Budget considerations
Regulatory Status:
EPA ID number (if you have one)
State permits or registrations
Recent inspections or violations
Compliance assistance needs
Our Process
1. Initial Consultation: Free consultation discussing your facility's needs, waste types, volumes, and compliance requirements. We answer questions and provide preliminary recommendations.
2. Facility Assessment: For larger facilities or complex needs, we conduct on-site waste assessments evaluating:
Waste generation points and quantities
Current storage and handling practices
Segregation procedures
Regulatory compliance status
Waste minimization opportunities
Container and service frequency recommendations
3. Customized Proposal: Detailed proposal including:
Service description and frequency
Container types and quantities
Pricing (transparent, itemized)
Compliance support services
Implementation timeline
Contract terms
4. Program Implementation:
Container delivery and placement
Staff training and orientation
Procedure development and documentation
Initial pickup scheduling
Compliance verification
5. Ongoing Service:
Scheduled pickups per agreed frequency
Manifesting and documentation
Certificates of destruction
Compliance monitoring and alerts
Periodic program reviews and optimization
Responsive customer service and support
6. Continuous Improvement:
Quarterly or annual business reviews
Waste minimization recommendations
Cost optimization opportunities
Regulatory update communications
Training refreshers
Why Healthcare Facilities Choose Us
Specialized Healthcare Expertise: Over three decades serving healthcare facilities from small practices to major medical centers. We understand healthcare operations, clinical workflows, and the unique challenges of pharmaceutical waste management in medical environments.
Complete Regulatory Compliance: Comprehensive expertise in EPA RCRA regulations, DEA controlled substance requirements, and state-specific pharmaceutical waste rules. We stay current with regulatory changes and ensure your program remains compliant.
Flexible Service Models: Services scaled and customized for facilities of all sizes and types - from solo physician practices to academic medical centers, from retail pharmacies to pharmaceutical manufacturers.
DEA-Authorized Services: Partnerships with DEA-authorized reverse distributors ensuring compliant controlled substance disposal with complete documentation including DEA Form 41 preparation and submission.
Cost-Effective Solutions: Proper waste segregation guidance, waste minimization consulting, and efficient service design reducing disposal costs while maintaining compliance. Transparent pricing without hidden fees.
Responsive Customer Service: Dedicated account management, 24/7 emergency response availability, rapid quote turnarround, and proactive communication. We understand healthcare facilities operate around the clock and need responsive partners.
Comprehensive Documentation: Complete manifest and certification documentation, electronic record access, audit support materials, and training documentation. Our documentation helps facilities demonstrate compliance during inspections and audits.
Training and Support: Customized training programs for clinical and non-clinical staff, ongoing compliance support, regulatory updates and alerts, and best practice recommendations. We're partners in your compliance program, not just a disposal vendor.
Environmental Stewardship: Commitment to environmentally responsible disposal methods, waste minimization and pollution prevention, recycling and recovery opportunities where available, and support for healthcare facilities' sustainability goals.
Pharmaceutical Waste Disposal by State
We provide pharmaceutical and healthcare hazardous waste disposal services throughout all 50 states. Click your state for specific information on state regulations, major healthcare facilities we serve, and local service details:
Northeast
Southeast
Midwest
Southwest
West
Contact Us for Pharmaceutical Waste Disposal
Call (800) 582-4833 or email info@hazardouswastedisposal.com
We're ready to help with:
Free consultations and quotes
Facility waste assessments
Regulatory compliance guidance
Emergency pharmaceutical waste removal
Scheduled service programs
DEA-compliant controlled substance disposal
Training and staff education
All your pharmaceutical and healthcare waste needs
Serving healthcare facilities nationwide, since 1992
Operating across all 50 states with expertise in pharmaceutical manufacturing, hospitals, clinics, pharmacies, long-term care facilities, research institutions, and all healthcare operations generating pharmaceutical waste.
Let us handle your pharmaceutical waste management so you can focus on patient care and pharmaceutical development. Contact us today for expert, compliant, cost-effective pharmaceutical waste disposal services.
