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  Specific waste: Patches

An increasing range of medicines are now available in patch form including:

• Scopolamine for motion sickness.
• Nicotine replacement (NicoDerm CQ, Habitrol).
• Pain relief (Duragesic [fentanyl], Lidoderm [lidocane])
• Anti-inflammatory drugs.
• Hormone replacement therapy.
• Contraceptive medicines (estrogen and progesterone, norelgestromin/ethinyl estradiol).
• Blood pressure drugs. 

Unused Patches: Unused patches should be returned to the pharmacy and/or a reverse distributor for credit whenever possible.  If the patch is a non-viable pharmaceutical waste, you must determine if it is a RCRA hazardous waste or a State-only dangerous waste.  Some unused patches like nicotine will be RCRA hazardous waste since it is a discarded chemical product containing a listed ingredient as a sole-active ingredient.  Also see Specific Waste: Nicotine.

Used Patches: Although a used patch’s pharmaceutical concentration may be below therapeutic doses, there is usually enough remaining on the patch to be considered a dangerous waste.  Unless the used patch is properly designated, you can assume it is a RCRA hazardous waste.  If you have determined the used patches are not RCRA hazardous, you can assume they are State-only dangerous waste eligible for management under the conditional exclusion.

Management of non-viable patches

RCRA hazardous waste patches: Includes unused patches with a P-listed or a U-listed sole-active ingredient or any patch that fails the RCRA Characteristics (also see the Profiling and Notification Factsheet, Pub # 07-04-026).

• A controlled substance: Follow the US Drug Enforcement Administration’s guidelines for transportation and witnessed destruction.  Manage as a RCRA hazardous waste at a RCRA-permitted facility.  It is a violation of the Dangerous Waste Regulations to dispose of these patches in the sewer, sharps container, or a regulated medical waste container.
• Not a controlled substance: Manage as a dangerous waste at a RCRA-permitted facility. It is a violation of the Dangerous Waste Regulations to dispose of these patches in the sewer, sharps container, or a regulated medical waste container.

State-only dangerous waste patches:  You can assume any patches that are not RCRA hazardous waste are State-only dangerous waste.  To determine that a patch is not a State-only dangerous waste, you must know the remaining concentration of the pharmaceutical in the patch as well as the acute toxicity information of the pharmaceutical. 

• A controlled substance: Follow the DEA guidelines for transportation and witnessed destruction.  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)].
• Not a controlled substance: 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)].