Are My Healthcare Facility’s Drugs Hazardous?

Posted by Wade Scheel on Wed, May 27, 2015 @ 05:01 PM

Read on to learn about the types of hazardous drugs commonly found in healthcare

Are My Healthcare Facility’s Drugs Hazardous?

The Environmental Protection Agency regulates hazardous chemicals through the Resource Conservation and Recovery Act (RCRA). When these chemicals become waste, they must be disposed according to EPA “Lists” or “Characteristics” of hazardous substances:

  • Discarded Commercial Chemical Products (U-Listed)
  • Acute Hazardous Waste (P-Listed)
  • Characteristic Waste
    • Ignitable,
    • Toxic,
    • Corrosive, or
    • Reactive

Read 5 Questions to Ask About Legal Pharmaceutical Disposal.


Most chemotherapy drugs fall into the U-Listed category. While chemotherapy drugs aren’t the only medication in this listing of toxic chemicals, they make up the majority in terms of volume of waste generated at healthcare facilities.


If the drug is on the P List, it is acutely hazardous and needs to be managed a little differently than the rest of the RCRA hazardous waste.  Generating less than 2.2 lbs of a P-listed drug in a calendar month will maintain your status as a conditionally exempt small quantity generator (CESQG) of hazardous waste.  Of course, as with many regulations, states may have more stringent requirements so it is always a good idea to double-check your state requirements.

The volume of P-listed drugs is small at most nonhospital facilities. P-listed waste must be disposed of with the correct paperwork, tracking, weighing and documentation of amount of P-listed waste generated every month. Some examples of P-listed drugs include:

  • Warfarin (Coumadin, Jantoven)
  • Nicotine patches, lozenges or gum
  • Physostigmine, physostigmine salicylate
  • Arsenic trioxide (Trisenox)

Characteristic Waste

The last section – the section many hazardous pharmaceuticals fall into, is the chemical combinations or ingredients that exhibit hazardous characteristics (Ignitability, Toxicity, Corrosivity and Reactivity). For example, unused alcohol pads and swabs can ignite. Multivitamins may have minerals, such as chromium or selenium, which, depending on the quantity, can make them toxic. Other toxic medicines are vaccines that contain thimerosal an additive with mercury and insulin with a cresol-based preservative.

The EPA doesn’t list all the chemicals that have hazardous characteristics, instead they assign different code that begin with the letter D to identify them by their characteristics.  The waste code for reactive chemicals is D003, Ignitable or Flammable is D001, Corrosive chemicals are D002, and Toxic chemicals are D004 through D043.  All of these drugs that have hazardous characteristics also require proper management and disposal.

Sound Complicated?

Hazardous waste regulations are complicated, but Stericycle can help “uncomplicate” the complicated. Stericycle’s Hazardous Drug Disposal Service (HDDS) provides the correct paperwork, online training, appropriate disposal containers, and proper hazardous waste disposal


ASK for a free drug waste review for my facility


Topics: Pharmaceutical Waste Disposal

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