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RCRA Regulations’ Subpart P Has Changed. Now What?

March 16, 2023

What Is Subpart P Regulations?

A doctor is covering their face with a clipboard that holds a piece of paper with a large question mark.The Environmental Protection Agency’s (EPA) RCRA Regulations’ Subpart P pertains to the way healthcare facilities handle, store, and transport hazardous waste. The EPA recognizes that healthcare is fundamentally different from other industries that generate hazardous waste, and Subpart P specifically governs the handling of waste.

All healthcare facilities and reverse distributors are prohibited from disposing of their hazardous waste pharmaceuticals down the drain. The sewer ban applies to healthcare facilities and reverse distributors of all sizes in all states, territories, and Indian country. In addition, with few exceptions, EPA discourages the sewering of any pharmaceutical, either by residents or any type of facility.

Healthcare Facilities that are Affected

The new rules apply to, but are not limited to:

  • Hospitals
  • Pharmacies
  • Clinics
  • Veterinary hospitals or clinics
  • Wholesale distributors or retailers
  • Pyrophoric, gases, aerosol, unknown, reactive, explosive and shock-sensitive materials
  • Ethers, THF, dioxane, and sodium azide

How the EPA Defines “Pharmaceutical”

  • Prescription medicine
  • Over-the-counter (OTC) drugs
  • Dietary supplements
  • Compounded drugs
  • Investigational drugs
  • Personal protective equipment (PPE) that has been contaminated with pharmaceutical waste
  • Pharmaceutical spill clean-up materials
  • Anything for which the Food and Drug Administration (FDA) requires a “drug fact” sheet

What All of This Means

All healthcare facilities, including very small quantity generators (VSQGs) and reverse distributors, are prohibited from discharging hazardous waste pharmaceuticals to a sewer system that passes through to a publicly owned treatment works (POTW). All healthcare facilities must properly and safely dispose of hazardous waste pharmaceuticals according to Subpart P.

Who Can Help?

GreenServ is a leader in safe and compliant medical waste disposal for all types of healthcare facilities and medical waste generators. We have created a turnkey Pharmaceutical Waste Disposal and Compliance Service to help facilities in Mississippi, Louisiana, Tennessee, and Arkansas successfully navigate the complex world of RCRA hazardous waste disposal. For more information, call us at 662-533-0940 or complete the form on this page. Our friendly experts are standing by to assist you.

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