Placeholder for snippet from air, land, water, toxics, waste, or other image

My Watershed


The following terms are defined for the purpose of the Interim Pharmaceutical Waste Policy only.  Some of the terms are defined in the Dangerous Waste Regulations, Chapter 173-303-040 Washington Administrative Code (WAC) and others were written to provide clarity for pharmaceutical waste managed under this policy.

Conditional Exclusion [WAC 173-303-071(nn)].  Pharmaceuticals that designate as state-only dangerous waste and not Resource Conservation and Recovery Act (RCRA) wastes are eligible for management under this conditional exclusion to the dangerous waste regulations. 

If managed as prescribed in the exclusion, the state-only pharmaceutical waste does not need to be counted towards generator status and does not need to be reported annually.  The Conditional Exclusion requires the incineration of state-only pharmaceutical waste at either:

(i) A facility permitted to incinerate municipal solid waste; or
(ii) A controlled combustion unit with:

(A) heat input greater than 250 million British Thermal Units per hour (BTUs/hr), and
(B) combustion zone temperatures greater than 1500 °F.

The Conditional Exclusion does not apply to any RCRA hazardous pharmaceutical waste.

Dangerous Waste. Any waste that designates under WAC 173-303-070(3).  Dangerous waste includes both RCRA hazardous waste and state-only dangerous waste.

Dual Waste.  Dangerous waste pharmaceuticals which are also infectious or potentially infectious.  Examples of dual waste include non-empty syringes containing dangerous waste pharmaceuticals with needles attached.  

P-listed hazardous waste.  Any commercial chemical products in which the listed chemical is the sole active ingredient.   Pharmaceuticals are commercial chemical products.  A commercial chemical product is a substance manufactured or formulated for commercial or manufacturing use which consists of the commercially pure grade of the chemical, any technical grades of the chemical, and all formulations in which the chemical is the sole active ingredient. 

Non-Viable Pharmaceutical.  A pharmaceutical that cannot be used for its intended purpose, sold, or returned to the manufacturer, wholesaler, or reverse distributor for credit.  This may include, but is not limited to:

  1. Expired pharmaceuticals
  2. Outdated items repackaged at the pharmacy
  3. Dropped pills
  4. Partial IVs, ampoules, ointments, creams, lotions, and inhalers
  5. Patient medications left at the hospital
  6. Samples

RCRA hazardous waste.  For the purposes of pharmaceutical waste, RCRA hazardous waste refers to any pharmaceuticals that designate as dangerous waste under WAC 173-303-080 through -090.  RCRA hazardous wastes include lists of certain discarded chemical products, manufacturing/industrial processes, or wastes with hazardous characteristics of ignitability, corrosivity, reactivity, or toxicity.  

Reverse Distribution.  The practice of shipping unwanted, viable pharmaceutical products to a third party with the intent of receiving manufacturer credit.

State-only dangerous waste.  Washington considers toxicity and persistence as criteria used to designate waste as dangerous in addition to the RCRA listing and characteristics.  For the purpose of the Interim Pharmaceutical Waste Policy, state-only dangerous waste refers to any pharmaceutical waste designating as dangerous waste under WAC 173-303-100 that is not a RCRA hazardous waste.

Viable Pharmaceutical.  A pharmaceutical that can be used for its intended purpose or returned to a manufacturer, wholesaler, or reverse distributor for credit is viable.  Viable pharmaceuticals are not subject to the dangerous waste regulations since they are considered product-like.  Any pharmaceutical disposed without credit is non-viable unless there is a documented change in credit status by the reverse distributor.