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Disposing of Epinephrine


Q: When we recently had our ACLS training the trainer said there are new rules for disposing of epinephrine. Can you tell me about them?

A: While the EPA's requirements under the Resource Conservation and Recovery Act (RCRA) aren't new, enforcement of them has taken a step up recently. The EPA in Region 2, which covers enforcement in New York, New Jersey, Puerto Rico, and the U.S. Virgin Islands among other territories, has been aggressively inspecting and enforcing hazardous waste requirements for hospitals. The fines have ranged from $40,000 to almost $290,000.

How can you avoid these kinds of fines? It depends on how epinephrine is used in your practice.

First, the EPA states epinephrine residue in a syringe is not P042. A syringe that has delivered a full dose of epinephrine (was used for its intended purpose) and contains only residual "epi" most likely can be disposed of in the infectious waste sharps waste stream, i.e. in the red biohazardous sharps container.

A partially used syringe that still contains epinephrine must be evaluated for hazardous waste characteristics and disposed of appropriately. Quality America recommends you dispose of it as a hazardous waste since the remaining epinephrine continues to have the original characteristic of toxicity, and therefore demonstrates one of the four characteristics the EPA says defines a hazardous waste.

For partially used syringes, obtain a black RCRA sharps container (available from Kendall, JJ Keller, Hospitec, and others). Arrange for a pick up of this waste by an appropriately permitted Hazardous Waste Disposal Company. This waste needs to be incinerated at a higher temperature than red bag biohazardous waste. Also, include "empty" multi-dose epinephrine vials in this container since for a container that has held a P-listed hazardous waste (i.e. epinephrine) to be "RCRA empty" all the contents must be removed and it must be triple rinsed. Since this isn't feasible in medical and dental practices, the container should be considered hazardous waste. Full vials obviously need to go in this container as well.

If you can arrange to return the unused (expired or about to expire) epinephrine to the manufacturer and have them dispose of it is a great money saving option.

For more information about the EPA's P-list, U-list, and what your practice has to do to be in compliance with hazardous chemical disposal laws, check out Tab 8 (Tab 5 for dental practices) of Quality America's OSHA Safety Program Manual.

Posted by Quality America on March 15, 2007 | Comments (3)


Thank you for your response Dr. Dunn. I am still unsure of the requirement for disposing of epinephrine. We keep epinehrine on hand just for emergency use. It may be used once a year or even less. That container could virtually sit for years before it would become full and ready for pick up. Does this still require a RCRA black sharps container if a single syringe still has remaining medication in it? Or is it appropriate to place it in a red sharps container. Does our Biohazard waste company pick these containers up or is it a specialized compnay?

Posted by: Judy Spark at April 18, 2007 04:04 PM

Many facilities are struggling with how to manage these concerns right now. Hospitals for a Healthy Environment (H2E), a joint project of the American Hospital Association, the Environmental Protection Agency, Health Care Without Harm, and the American Nurses Association, is one organization that's working to provide guidance to healthcare facilities regarding managing hazardous waste.

Here's their website: http://www.h2e-online.org/

Strictly speaking, if the syringe has more than a residual amount of epinephrine remaining, it needs to be disposed of as RCRA hazardous waste and not in the red sharps container.

It's possible that your biohazard waste company also has a permit authorizing them to pick up hazardous chemical waste (i.e. black RCRA containers). You would have to inquire with your company representative. Most likely, this would be a specialized company. Since your waste generation is so low, you may be able to partner with a local hospital, chemotherapy clinic, or other facility that generates larger quantities of RCRA waste to assist you in managing this waste stream.

Posted by: Sarah Alholm at April 20, 2007 01:39 PM

Thank you for your prompt response. The idea of having a larger facility dispose of this was a great idea and I will look further into that option. I have contacted my biohazard waste company and at present they do not pick up RCRA containers but are in the process of being trained to do so.

Posted by: Judy Spark at April 20, 2007 03:16 PM

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