HWTR home > Pharmaceuticals home > What is DW?

  What is Dangerous Waste?

In Washington state, we have been given authority from the federal government to implement the Resource Conservation and Recovery Act (RCRA). RCRA defines “hazardous waste.” The federal government allows states to be more stringent when regulating wastes, to protect the environment. In Washington state, it was decided to add additional types of waste to the law. We call this larger universe of regulated waste “dangerous waste.”

To manage pharmaceuticals under our conditional exclusion, or to determine if any waste is a dangerous waste, a process called “designation” is used. Designation consists of a number of steps. Ecology has prepared a number of documents to help you through this process and links to these are provided below.

The steps can be summarized as:

1. Compare the sole active ingredient to the list in the Dangerous Waste Regulations (Washington Administrative Code chapter 173-303, section -9903). Do this step if disposing of an unused pharmaceutical or a spilled pharmaceutical.
2. Determine if the pharmaceutical is ignitable.
3. Determine if the pharmaceutical is corrosive.
4. Determine if the pharmaceutical has certain constituents in it at certain amounts. This is done based on the ingredients of the waste or using a testing procedure called the Toxicity Characteristic Leaching Procedure.
   
   If the pharmaceutical is not a hazardous waste after these steps, then you can choose to continue using the steps below or you can decide to manage the pharmaceuticals as if they are dangerous waste.
    
5. Determine the toxicity of the pharmaceutical by determining the toxicity of each ingredient using toxicological studies
6. Determine if the pharmaceutical will persist (not break down) in the environment by assessing the total halogenated hydrocarbons and the polycyclic aromatic hydrocarbons in the pharmaceutical.

Know the total amount of all dangerous waste generated at your facility is important because it will determine your facility’s generator status. “Generator” refers to a facility that generates dangerous or hazardous waste, in any amount. Generator status is a concept used to determine the level of regulation applied to each facility and it determines some of the options for disposal.

For further assistance with designation, you can call the regional office that serves your area and speak with a hazardous waste compliance inspector. Or try our on line resources:
Hazardous Waste Regulatory Information and Assistance
The Hazardous Waste and Toxic Reduction Program home page 

 

Some examples of pharmaceuticals that designate as hazardous waste.

Epinephrine is on the list of sole active ingredients as a P listed waste. Epinephrine would designate as a dangerous waste under the federal portion of the law. This waste is not eligible for management under the conditional exclusion.

Some wart removal medications are ignitable. This waste is a dangerous waste under the federal portion of the law and is not eligible for management under the conditional exclusion.

Mercurochrome has enough mercury in it to be characteristic waste under the federal portion of the law. This waste is not eligible for management under the conditional exclusion.

Extra strength aspirin fails the Washington state toxicity criteria. This is the only reason it designates as a dangerous waste. This waste can be managed under the conditional exclusion, so if it is disposed of by incineration in a controlled combustion unit with a heat input rate greater than 250 million British thermal units/hour, a combustion zone temperature greater than 1500 degrees Fahrenheit, or a facility permitted to incinerate municipal solid waste.