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  Specific waste: Epinephrine

Epinephrine is listed on the discarded chemicals list (Chapter 173-303-9903 WAC).  When a product with epinephrine as the sole-active ingredient is discarded or not used for its intended purpose, it is a RCRA hazardous waste with a listed waste code of P042. 

Epinephrine products include:

  • Pre-filled syringes.
  • Vials and ampoules.
  • IV bags with very dilute solutions of epinephrine.

In Washington State, salts of epinephrine are also P042 if they are the sole-active ingredient. Ecology disagrees with the US Environmental Protection Agency’s (EPA) interpretation that epinephrine salts are not P042 listed waste. 

The Department of Ecology considers salts of epinephrine to be P042 since the sole-active ingredient is still epinephrine.  The primary purpose of the salt is to make the epinephrine soluble.  Salts of epinephrine include epinephrine hydrochloride and epinephrine bitartrate, but not norepinephrine.

Note:  The Department of Ecology is delegated by EPA to enforce RCRA, the federal hazardous waste regulations.  Delegated authorities must be at least as stringent as EPA’s regulations, and may be more stringent.  Delegated states must make their own regulatory interpretations.  Our Dangerous Waste Regulations [Chapter 173-303 WAC] are more stringent than RCRA because we have State-only criteria for toxicity and persistence [Chapter 173-303-100 WAC].

Designation of waste epinephrine

Epinephrine for injection:  An unused or partially administered dose of injectable epinephrine is considered a discarded chemical product since it is not used for its intended purpose.  

  • A discarded formulation that has epinephrine or a salt of epinephrine as the sole-active ingredient is a P042 listed waste.
  • Residues of formulations with epinephrine or a salt of epinephrine are a P042 acutely hazardous waste. 
    • The container is also a P042 listed waste since it is not practical to triple-rinse pharmaceutical containers.
  • Formulations where epinephrine is not the sole-active ingredient are not RCRA listed waste.  You must determine if it is a RCRA characteristic waste [Chapter 173-303-090 WAC] for ignitability, corrosivity or reactivity.
    • For example, a syringe with epinephrine and lidocaine is not considered a P042 waste since there is more than one active ingredient.  However, if the formulation’s pH is less than or equal to 2, it is a RCRA hazardous waste for corrosivity with a waste code of D002.
  • If the epinephrine is not a listed waste and is not a RCRA characteristic waste, you can assume it is a State-only dangerous waste. (WT02 down to 0.01%)
Epinephrine containers:  Containers that held epinephrine are considered P-listed waste since the residue inside is not used for its intended purpose.  Containers can include syringes, IVs, vials and ampoules.
  • The container is dangerous waste unless it is triple-rinsed. You must manage the rinsate as P042 listed waste.  It is not practical to triple-rinse pharmaceutical containers so they are usually managed as hazardous waste. 
    • Note: Ecology differs from EPA’s interpretation that the residue remaining inside a syringe has been used for its intended purpose.  In Washington State, the used epinephrine syringe is still a P042 listed waste. 
  • Some containers, like syringes, can qualify as dual waste.  See also Specific Wastes: Dual Waste.

Management of waste epinephrine

Viable epinephrine:  Epinephrine that is eligible for credit from a manufacturer, wholesaler, or reverse distributor is a viable pharmaceutical and not considered waste.  Viable pharmaceuticals include any unused and/or unopened pharmaceutical that can be used or receive a credit.  You must manage items not receiving a credit as waste.

RCRA hazardous epinephrine waste:  This includes:

  1. Any non-viable formulations with epinephrine or epinephrine salts as the sole-active ingredient (Chapter 173-303-080 WAC).
  2. Containers that held formulations with epinephrine or epinephrine salts as the sole-active ingredient.
  3. Any formulation with a RCRA characteristic of ignitability, corrosivity, reactivity, or toxicity (Chapter 173-303-090 WAC).

It is a violation of the Dangerous Waste Regulations to dispose of these pharmaceuticals in the sewer, sharps container, or a regulated medical waste container.  Manage these as dangerous waste at a RCRA-permitted facility.

    • Under the Dangerous Waste Regulations, accumulating more than 2.2 pounds (or 1 liter) of any P-listed waste will make you a large quantity generator.  See the regulations for more information: Chapter 173-303 WAC.
    • Under the Interim Enforcement Policy, the listed waste will not count towards your generator status if it is sent to a RCRA-permitted incinerator as RCRA hazardous waste on a Uniform Hazardous Waste Manifest. 
  • See also: Pharmaceutical Waste Management Flowchart

State-only dangerous waste:  You can assume any epinephrine formulations that are not RCRA hazardous waste are State-only dangerous waste.  To determine the waste is not a State-only dangerous waste, you must know the concentration of epinephrine and all other ingredients and acute toxicity information of those ingredients.

  • Manage as either a dangerous waste at a RCRA-permitted facility or as excluded waste at an incinerator meeting the criteria of the conditional exclusion [Chapter 173-303-071(3)(nn)]. 

It is a violation of the Dangerous Waste Regulations to dispose of these pharmaceuticals in the sewer, in a sharps container, or in a regulated medical waste container destined for landfill.

Resources:

Delegation of RCRA to states by EPA