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  Specific waste: Nitroglycerin

Nitroglycerin is a chemical on the discarded chemicals list of chemicals (Chapter 173-303-9903 WAC).  In most scenarios, if a product with nitroglycerin as the sole-active ingredient is discarded, it would be considered a RCRA hazardous waste with a listed waste code of P081. 

In 2001, EPA made a revision to the mixture and derived-from rules (66 FR 27286).  This excluded all P- and U-listed wastes that are listed solely for an ignitability, reactivity and/or corrosivity characteristic if they no longer exhibit that characteristic. 

Washington State adopted this rule in 2003.  As a result, medicinal formulations of nitroglycerin are no longer considered P-listed waste because it is weak and non-reactive. For more information, please refer to Chapter 173-303-070(2)(C)(I) WAC

All nitroglycerin formulations must still be evaluated for the other RCRA hazardous characteristics (Chapter 173-303-090 WAC) and Washington State-only criteria (Chapter 173-303-100 WAC).

Management of waste nitroglycerin

Viable nitroglycerin:  Nitroglycerin 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 receive a credit.  Items not receiving a credit must be managed as a waste.

RCRA hazardous nitroglycerin waste: Includes any non-viable formulations of nitroglycerin that designate under the RCRA Characteristics of Ignitability, Corrosivity, Reactivity or Toxicity (Chapter 173-303-090 WAC). 

  • Manage as a dangerous waste at a RCRA-permitted facility. 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.  For example, a nitroglycerin injection solution may contain 5 mg nitroglycerin, 30% alcohol (v/v), 30% propylene glycol and pH adjusted water.  Since the alcohol concentration is more than 24%, the formulation is still a RCRA hazardous waste for the characteristic of ignitability (waste code D001). 

State-only dangerous waste:  You can assume any nitroglycerin formulations that are not RCRA hazardous waste are State-only dangerous waste.  To determine that it is not a State-only dangerous waste, you must know the remaining concentration of the nitroglycerin and any other ingredients as well as the 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)]. 

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