How can our facility determine which medications are considered hazardous?

Due to the sheer number of medication variations including new product introductions, there is no single source answer. In fact, the federal government has not updated the U-List and P-List since 1975. To make matters more challenging, each facility is responsible for identifying hazardous waste.

Under RCRA, a solid waste is considered hazardous waste if it exhibits one of four characteristics—ignitability, corrosivity, toxicity, or reactivity, or if it is specifically named on one of the four EPA lists of hazardous waste, P, U, F, and K, in 40 CFR §261.2(d). Drugs listed under P and U include specific unused chemicals; drugs under U are toxic, while those under P are considered acutely toxic.

Rx Destroyer recommends a combination of efforts including staff and consulting pharmacist review site formulary. If additional assistance is required, there are a number of outside analysis firms available to perform waste analysis. Also, be aware of local, state and tribal regulations may vary as to which drugs and what quantity qualify them as hazardous.