On May 19th, 2008, EPA posted an interpretation letter which extends the previous 1994 exclusion of residual epinephrine in a used, discarded syringe to other P- and U- listed drugs, unless they exhibit another characteristic of hazardous waste, such as ignitability.
While the epinephrine salts are no longer P-listed as of October 15th, 2007, this action will affect other P-listed drugs, such as arsenic trioxide and physostigmine salicylate. Prior to this interpretation, any needle/syringe combinations used to transfer these drugs had to be managed as non-empty P-listed waste, due to the triple rinsing rule. Assuming states adopt this exclusion, that will no longer be the case. In the above examples, the arsenic trioxide syringe should be managed as trace chemotherapy waste and the physostigmine salicylate syringe can be managed in a red sharps container.
For additional information, refer to the EPA's RCRA Online Website.
PharmEcology® Associates, LLC of Wauwatosa, WI was founded in 2000 and provides pharmaceutical waste management consulting services to the healthcare industry through seminars, on-site risk assessments, and other custom consulting services, in addition to the PharmE® Waste Wizard and PharmE® Inventory Analysis. Contact us at 414-292-3959 or email us at firstname.lastname@example.org.