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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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