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  Specific waste: Vitamin and mineral preparations

Vitamin and mineral preparations without added pharmaceuticals do not qualify for either the Conditional Exclusion for Pharmaceutical Wastes Chapter 173-303-071(3)(nn) WAC or the Interim Enforcement Policy. This is because they do not meet the definition of a “drug”, see RCW 69.41.010 Legend drugs (pharmaceutical drugs). These preparations are subject to all applicable requirements of the Dangerous Waste Regulations.

Unused, unopened and undiluted vitamin and mineral products: Return as a product to reverse distributor or manufacturer if credit is available If reverse distributors or manufactures cannot provide credit for unused vitamin and mineral product, they become a waste and cannot be returned.

Expired product and unused preparations (diluted and undiluted): These products and preparations are waste. Both diluted and undiluted forms may have constituents that cause them to designate as a dangerous waste.

Designation of Vitamin & Mineral Preparation Wastes

RCRA hazardous waste: Includes any waste that fails under the federal RCRA Characteristics of Ignitability, Corrosivity, Reactivity or Toxicity, Chapter 173-303-090 WAC. The most common concern is the concentration of RCRA toxicity characteristic metals.

  • These metals include: Arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver.
    • For example: oil-soluble prenatal formulations and some homeopathic remedies contain mercury or mercury compounds.

State-only dangerous waste: If the wastes do not designate as a RCRA hazardous waste, they must be evaluated to determine if they are a State-only dangerous waste. To determine that a waste is not a State-only dangerous waste, you must know the concentration of all constituents in the waste and their acute toxicity, Chapter 173-303-100 WAC

You may reference the Pharmaceutical Waste Designation Flowchart since the designation process is the same.

Management of vitamin and mineral preparation wastes

If the wastes designate as a RCRA Hazardous Waste or State-only dangerous waste, they must be stored, labeled, accumulated and disposed per the applicable requirements of the Dangerous Waste Regulations. The publication titled Guide for Dangerous Waste Generators In Washington summarizes these requirements based on your facility’s generator status.

When waste vitamin and mineral preparations designate as a dangerous waste, they do not qualify for either the Conditional Exclusion for Pharmaceutical Wastes [Chapter 173-303-071(3)(nn) WAC] or the Interim Enforcement Policy. Facilities that are a medium or large generator of dangerous wastes must dispose at a RCRA-permitted incinerator. Small quantity generators dispose of their dangerous wastes by shipping off-site to a permitted TSD or to a permitted to manage moderate risk waste or other permitted solid waste facility.

Note: 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.