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Hazardous Pharmaceuticals

The next category of waste pharmaceuticals is RCRA Hazardous pharmaceuticals.

What is the RCRA?

RCRA stands for the Resource Conservation and Recovery Act. This is the set of laws that governs all aspects of managing hazardous materials. RCRA also defines which chemicals are considered Hazardous by the Federal EPA and Department of Transportation. The RCRA laws were written before the pharmaceutical revolution, so there are many drugs currently under review to be added to the federal RCRA list.

Which pharmaceuticals are on the hazardous list?

Though there are thousands of chemicals on the RCRA list, less than forty specific pharmaceuticals appear on the list. Still many others are considered hazardous under this law due to a particular characteristic it displays like corrosivity, flammability, toxicity and reactivity. The RCRA regulated chemicals are divided into several lists. Hazardous pharmaceuticals can be found on three of them, the P-list, U-list and D-list. Below is an abridged table containing examples of RCRA hazardous pharmaceuticals.

Example RCRA Regulated Pharmaceuticals 

Note: must contain constituent as sole-active ingredient and be unused or discarded

Waste Code Constituent of Concern Product Name Examples
P001 Warfarin & salts (concentration
> 0.3%)
Coumadin, Warfarin
P042 Epinephrine Adrenalin, EpiPen, Eppy/N, Epifrin, Epinal, Anaphalaxis kit, Epinephrine (inhalants, injectibles, kits), Racepinephrine, Racord, Primatene aerosol inhaler
P075 Nicotine & salts Nicotine patches, Habitrol, Nicoderm, Nicorette, Nicotrol, Tetrahydronicotyrine
U058 Cyclophosphamide CTX, Cytoxan injection, Lycophilized/VHA Plus, Neosar, Procytox
U010 Mitomycin C Mitomycin, Mitomycin C, Mutamycin, Mutamycin VHA Plus
D009 Mercury Any U151 listed waste, any drug w/ thimerosal or phenylmercuric acetate (vaccines, eye drops, nasal spray, etc.)
D001 Flammable aerosol propellants meeting the DOT definition of compressed gas (261.21(a)(3)) Primatene aerosol

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