Hazardous Listed Pharmaceutical Waste: P, U, and D Drugs

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Proper management of hazardous pharmaceutical waste is a critical concern for healthcare facilities that handle medications. Proper segregation and disposal of hazardous waste is essential to maintain regulatory compliance and protect the environment and public health.

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In the United States, the Environmental Protection Agency (EPA) regulates hazardous waste under the Resource Conservation and Recovery Act (RCRA).

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Defining Pharmaceutical Listed Wastes

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Hazardous Pharmaceutical listed waste is any prescription or over the counter drug that goes unused and is considered hazardous waste by the Resource Conservation and Recovery Act.

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The EPA classifies hazardous waste based on a specific waste code. Two of the more common EPA codes within healthcare facilities and pharmacies include P and U listed hazardous wastes.

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Pharmaceutical waste can be categorized as non-hazardous pharmaceutical waste or hazardous pharmaceutical waste and it is important to contract with a licensed hazardous or medical waste disposal company for proper treatment and disposal.

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If the waste contains a chemical listed on the P or U list, is unused, and is in the form of a commercial chemical product (the substance is the sole active ingredient), then it is a hazardous pharmaceutical and must follow specific hazardous waste guidelines. This is especially important for managing listed waste in healthcare settings.

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P Listed Drugs & Pharmaceutical Wastes

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P listed hazardous waste is defined as "acutely toxic" by the Healthcare Environmental Resource Center (HERC). Acutely toxic means the drug can cause death or irreversible illness even at low doses. As little as one kg generated can classify your facility as a large quantity generator of hazardous waste.

According to HERC, examples of the more common P-listed drugs found in health care facilities include:

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3-benzyl chloride (P028)

Arsenic (P012)
Arsenic Trioxide (P012)
Chloropropionitrile (P027)
Cyanide Salts (P030)
Epinephrine (P042)
Nitroglycerin (P081)
Phentermine (P046)
Phenylmercuric Acetate (P092)
Physostigmine Salicylate (P199)
Potassium Silver Cyanide (P099)
Sodium Azide (P105)
Strychnine (P108)

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Empty containers that previously held P listed drugs are also deemed hazardous waste unless they have been triple-rinsed by RCRA standards. You can view a full list of 239 P-listed chemicals here.

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U-Listed Drugs & Pharmaceutical Wastes

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U-Listed wastes are toxic and hazardous as well, but are subject to fewer regulations than P-listed wastes. There are about 472 total U-Listed substances, with 66 commonly found in healthcare settings.

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Some examples of U listed drugs include:

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• Cyclophosphamide (U058)
• Lindane (U129)
• Chloroform (U044)
• Formaldehyde (U122)

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For a full list of 472 U listed chemicals click here.

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Hazardous Wastes Differences

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Both P and U list drugs are regulated under the RCRA as hazardous waste, but the main difference between P and U listed hazardous waste is the hazard level they pose. U list drugs have a lower toxicity level than P list drugs and therefore typically have less stringent requirements for management.

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Alongside P and U listed pharmaceutical waste, there are other hazardous wastes, such as D listed substances, which include corrosive hazardous wastes and those exhibiting characteristics like corrosivity, reactivity, ignitability, or toxicity.

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D Listed Pharmaceuticals

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The RCRA recognizes pharmaceutical waste as hazardous if it has one of the four characteristics for D- listed waste: toxic, corrosive, reactive, or ignitable. These wastes are assigned waste codes starting with the letter D under the EPA's hazardous waste ID system.

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Ignitability (D001)

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Ignitable wastes are any items able to readily catch fire that pose a significant risk of combustion. Common examples of the ignitable characteristic include:

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• Solutions with more than 24% alcohol content
• Flammable liquids (Can ignite at less than 140 degrees Fahrenheit)
• Flammable compressed gasses and oxidizers
• Non-liquid materials able to catch fire through friction, absorption of mixture, or spontaneous chemical changes under normal conditions.

Corrosivity (D002)

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Corrosive items are able to corrode away metals through chemical reactions. Examples of the corrosive characteristic include:

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• Aqueous solutions with a pH less than or equal to 2 or greater than or equal to 12.5
• Liquids that can corrode steel at a rate greater than 6.35 mm (0.250 inches) per year at 55°C (130°F)

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Toxicity (D004 to D043)

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Toxic wastes contain harmful chemicals that pose a significant risk to human health and the environment - contaminating water, air, and soil. Common examples of the toxicity characteristic include:

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• Wastes with specific toxic metals, such as arsenic, cadmium, or lead
• Materials containing certain toxic organic compounds, like benzene or trichloroethylene
• Wastes with harmful pesticides or herbicides, such as endrin or lindane

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Reactivity (D003)

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Reactive wastes are substances that can react under certain conditions, such as exposure to water, air, or heat, and may pose risks of explosions, fires, or the release of toxic gases. Common examples of the reactive characteristic include:

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• Substances that produce toxic gases or fumes when mixed with water or air
• Materials that can explode or generate dangerous amounts of heat when exposed to heat or a flame
• Compounds that can react violently with water or other substances

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Consequences of Improper Disposal

Proper disposal is essential and the responsibility is on the waste generator to ensure RCRA regulations are followed and each stream of waste reaches the appropriate final destination of disposal and is disposed of at a licensed medical incineration site.

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Some consequences of improper disposal of hazardous waste include:

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• Environmental damage: Hazardous substances accumulate in the soil, air, and pollute groundwater which can result in bioaccumulation.
• Regulatory consequences: Non compliance with local, state, and federal regulations can result in serious penalties.
• Human Health risks: Direct exposure to hazardous substances, such as P-listed wastes, can cause death and irreversible illness even at low doses

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Pharmaceutical Waste Subpart P

Subpart P of Title 40 Code of Federal Regulations offers a set of EPA regulations and provisions aimed to improve public health and environmental safety regarding hazardous waste pharmaceuticals. Within the subpart are standards for handling. labeling, and disposing of hazardous pharmaceutical waste.

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Disposing of Pharmaceutical Waste

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Disposing of pharmaceutical waste should involve segregation at the point of generation. Non-hazardous pharm waste should go into a blue and white container clearly labeled for incineration only. Trace amounts of chemotherapy waste can be disposed of using trace chemotherapy waste containers. If you are dealing with a hazardous waste it must be segregated and stored using an approved black hazardous waste container.

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Here is an example of an RCRA hazardous waste container:

Looking for a Pharmaceutical Waste Disposal Expert?

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Eco Medical has been disposing of medical and pharmaceutical waste in California since 2013 and is licensed to transport and dispose of all regulated medical waste streams. If you have any questions regarding medical waste, chemotherapy drugs, p listed waste, or non-hazardous pharmaceutical waste - contact us for guidance on proper disposal and a free quote for service.

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