What is Pharmaceutical Waste and How Do You Discard It?

Everyone has one or two bottles of expired medication rattling around in the back of the medicine cabinet.  Some of those bottles contain common OTC drugs, like ibuprofen, or they could be controlled substances, like an anxiety medication.  If you’re an individual, you can bring those old meds to a take-back location like a pharmacy or local healthcare facility.  But what if you’re at the pharmacy or local healthcare facility?  Now you have to deal with your own pharma waste, plus your neighborhood’s. 

Pharmaceutical waste disposal suddenly becomes a lot more complicated, and it’s your responsibility.  And when you’re getting audited, you’ll need to show that you’ve handled it correctly…and legally.  Here’s how to identify what pharmaceutical waste actually is, how it’s categorized, and what proper disposal looks like.

What Counts as Pharmaceutical Waste?

Pharmaceutical waste is any medication that is no longer needed.  This includes unused, expired, contaminated, or leftover medications. 

Prescription drugs, OTC medications, painkillers, compounded preparations, supplements, ointments, and antibiotics are all pharma waste.  In some cases, it also includes the containers those drugs were in.  Basically, if it was a drug and it’s now being thrown away, it’s pharmaceutical waste.

But there’s a catch. Pharmaceutical waste disposal breaks down into a few different categories, and each of those categories has different rules for processing.

The 3 Categories of Pharmaceutical Waste

Pharmaceutical waste generally breaks down into three buckets:

Hazardous waste pharmaceuticals.  These are drugs that meet the EPA’s definition of hazardous waste under the Resource Conservation and Recovery Act (RCRA).  These include the EPA’s P- and U-listed waste categories.  These cannot be thrown in the trash, poured down a drain, or incinerated without following specific procedures.

• Chemotherapy agents
• Nitroglycerin
• Warfarin
• Pentobarbital
• Epinephrine

Controlled substances.  DEA-scheduled drugs have their own disposal rules and are governed by the Controlled Substances Act and DEA regulations.  They’re tracked from acquisition to destruction, and destruction methods must meet DEA standards.

• Opioids
• Sedatives
• Stimulants
• Methadone
• Ketamine 

Non-hazardous pharmaceutical waste.  Drugs that don’t meet the RCRA hazardous threshold and aren’t “scheduled” drugs still can’t be discarded like trash.  Many states have their own standards, but every part of the US calls for segregation and documented disposal.

• Over-the-counter drugs
• Antibiotics
• Vitamins and supplements
• Topical ointments and creams
• Contraceptives and abortifacients

What About Injectables?

Auto-injectors and injectable drugs like insulin, weight-loss pens, naloxone, and epinephrine are a different case.  Although the medications they contain are technically pharmaceutical waste, injectables should be discarded as sharps.  This way, they’ll prevent contamination and sharps injuries.  However, when those same drugs or compounds are stored in other formats (like a nasal spray or a solution in a vial) then they are treated like other types of pharmaceutical waste.

Here’s Where Most Facilities Get It Wrong

You can sort and separate to your heart’s content, and you may get it 100% right.  But what you do with it after sorting…that’s a little trickier.

Flushing medications is still surprisingly common, even though it’s been prohibited for hazardous waste pharmaceuticals for years.  Staff who don’t know how to handle pharma waste may throw it into the regular trash, which may be against the law.  If you don’t know the RCRA hazardous waste management requirements and mis-sort your waste, you might end up with heavy fines.

Improper pharmaceutical waste disposal can be seriously detrimental to the environment, too.  Pharma waste is a persistent pollutant because drugs are designed for stability.  Flushing or throwing pharma waste can contaminate water systems, soil, plant and animal life, or even encourage the development of antibiotic-resistant bacteria (aka: superbugs).

Even as EPA regulations change, the environmental, economic, and reputational impact of improper pharma waste management never truly goes away. 

How to Get Pharmaceutical Waste Disposal Right Every Single Time

Done correctly, pharmaceutical waste management is as easy as 1-2-3:

1. Identify and segregate waste at the point of generation.  Know what’s hazardous, what’s a controlled substance, and what’s non-hazardous.  Use clearly labeled containers so there’s no mistake.
2. Work with a licensed pharmaceutical waste disposal provider.  Choose a provider who can handle pharmaceutical waste under both EPA and DEA requirements, transport it properly, and document destruction.  As your waste generation volume changes, they should make it easy to adjust your pickup schedule accordingly.
3. Keep your records.  The EPA requires waste characterization records to be retained for at least three years from the date they are performed.  Keystone securely stores all your documentation so you can access and review anytime.

Keystone Will Help You Sort It Out

A lot of facilities are paying for disposal services that don’t actually match their waste volume, either because their needs have changed, or because their contract is standardized and inflexible.  For a smaller clinic or a non-healthcare setting, look for services that fit your actual waste volume.  Even if it fluctuates.

The overlap between EPA and DEA regulations, combined with state-level variation, means there’s a lot of room for error…and audits do happen.  Keystone Med Waste works with healthcare facilities to make pharmaceutical waste disposal straightforward, from pickup scheduling to documentation storage. 

Not sure how to handle your pharma waste?  We don’t want you to get it wrong, either!  Call or email Keystone for fast, personalized support.