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  Specific waste: Mercury-containing pharmaceuticals

Mercury is used as a preservative (e.g., thimerosal) in medical preparations such as vaccines (influenza, hepatitis B, DPT), ointments (ear medicines, hemorrhoid medication), contact-lens solutions and nasal sprays.

It is often difficult to determine whether a drug contains mercury. Ecology recommends you require your vendors to identify all mercury containing products and provide mercury free formulations when they are available.

Ecology recommends managing all mercury containing pharmaceuticals as dangerous waste

Most wastes containing mercury are dangerous waste. Usually medical personnel do not have adequate information to designate mercury containing pharmaceuticals without testing. Mercury containing pharmaceuticals can designate as a D009 Toxic Characteristic RCRA waste or a State-Only Toxic Criteria Waste.

Designation of pharmaceutical wastes that contain mercury

RCRA hazardous wastes: Includes any non-viable formulation that designates under the RCRA Characteristic of toxicity (D009) when the concentration of mercury is greater than 0.2 ppm.

Example of a RCRA hazardous waste:

  • Thimerosal and other mercury-containing ingredients (D009)

State-only dangerous waste: You can assume any non-viable formulations that are not a RCRA hazardous waste are State-only dangerous waste. To determine that it is not a State-only dangerous waste, you must know the concentration of the mercury constituent as well as the acute toxicity information, Chapter 173-303-100 WAC.

Management of waste mixtures

Viable formulations: Unused formulations that are eligible for credit from a manufacturer, wholesaler, or reverse distributor are a viable pharmaceutical and not considered waste. Viable pharmaceuticals include any unused and/or unopened pharmaceutical that receive a credit. Items not receiving a credit must be managed as a non-viable waste.

RCRA hazardous waste: Dispose as a hazardous waste at a RCRA-permitted facility.

State-only dangerous waste: Dispose 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) WAC.

  • See also: Pharmaceutical Waste Management Flow Chart
  • NOTE: Do not dispose of any Mercury wastes down the drain or into soiled linens destined for the laundry. Authorization by your local sewer authority is required for disposal of any process waste to sanitary sewer. Sewer agencies may NOT accept dangerous wastes. The sewer authority will also consider how the compounds will affect their treatment system and the microorganisms.

    Mercury in the Environment. Mercury-containing products, regardless of their designation, can lead to contamination when thrown in the trash, where they might be crushed or incinerated.

    Mercury can evaporate into the air where it can then be deposited into water and soil. Fish accumulate mercury in their bodies. This in turn can be a source of mercury exposure to people who consume the fish. Children and fetuses are the most vulnerable to the effects of mercury. Exposure can affect learning and behavior later in life.

    Resources Available

    Mercury in Medicine
    Thimerosal Content in Vaccines
    Thimerosal FAQ
    DOH Information on Thimerosal
    Ecology’s Mercury Home Page