mixing pharmaceutical waste streams

Mixing Pharmaceutical Waste Streams Will Cost You Money

It’s something that happens all too often – medical waste generators inadvertently mix incompatible waste streams. Medical waste management comes with stringent guidelines mandated by regulatory agencies. To properly handle, transport, and dispose of medical waste without risk, you and your staff must be trained on proper procedures and your waste services partner should be highly experienced and knowledgeable. Otherwise, you risk endangering the health of your patients and employees or incurring fines and penalties for non-compliance. Proper segregation is the cornerstone of compliant waste management. Let’s look at why mixing pharmaceutical waste streams will cost you money, as well as time and resources.

Why Proper Pharmaceutical Waste Segregation Matters 

Different types of medical waste require different disposal methods. Each waste stream must be handled and managed separately. State and federal guidelines clearly lay out standards for such procedures. Pharmaceutical waste is one of the more complex medical waste streams to manage and is managed separately from regulated medical waste (RMW). For example, pharma waste should never be disposed of in a sharps container or with red bag waste. In turn, non-hazardous pharmaceutical waste should not be mixed or co-mingled with hazardous pharma waste. If it is, the entire mixture is considered hazardous waste under the Resource Conservation and Recovery Act (RCRA). This means the entire mixture must be managed and disposed of as hazardous waste, even if only a small portion is hazardous.

Now, more than ever, it’s important to streamline your hazardous pharmaceutical waste segregation. Not only does mixing pharmaceutical waste streams make all the waste hazardous due to contamination and increase the resources needed to manage it. If non-hazardous pharma waste becomes contaminated, your disposal costs will sharply increase. Hazardous pharma waste disposal has always cost more than non-hazardous disposal, but now there is a marked difference. Here’s why.

Backlog of Containerized Hazardous Waste Needing Incineration 

In early June 2021, the Environmental Protection Agency (EPA) became aware of backlogs at some commercial hazardous waste incinerators. There were many contributing factors, such as winter storms that caused shutdowns, labor shortages due to the COVID-19 pandemic, and increased waste generation as the economy recovered from the pandemic. This created a problem for hazardous waste generators due to RCRA storage time limits.* For compliance, large quantity generators (LGQs) must transport hazardous waste off-site for treatment within 90 days. Small quantity generators (SQGs) have a timeline of 90 days.


In August of 2021, an EPA memorandum offered relief for hazardous waste generators and permitted hazardous waste treatment, storage, and disposal facilities (TSDFs). The memo detailed options under RCRA for extensions on  time-based accumulation limits. Basically, the memo highlighted existing regulatory options for LQGs and SQGs to request 30-day extensions. EPA also stated that there would be no limits on the number of extensions that could be granted. Unfortunately, what EPA understood to be a temporary backlog across the United States did not resolve.

Since the backlog did not resolve in early 2022, as EPA expected, LQGs and SQGs are running out of storage space, which means less space for containerized hazardous waste pharmaceuticals. In August of 2022, an update was posted on the EPA website that the memo was still in effect. However, the original memo does not address hazardous waste pharmaceuticals, which continue to accumulate. Furthermore, even with time extensions, neither Very Small Quantity Generators (VSGQs) or SQGs received relief from EPA on storage amounts. Because of the nationwide backlog of containerized hazardous waste awaiting incineration, healthcare facilities and healthcare waste service providers are challenged to find permitted hazardous waste incinerators that will accept shipments of RCRA hazardous pharmaceutical wastes. (Many healthcare facilities generate relatively small quantities of hazardous waste, and the incinerators are prioritizing LQGs and larger shipments.) 

Increased Disposal Costs for Mixing Pharmaceutical Waste Streams

The bottom line? The incineration backlog means increased costs for treatment and disposal of hazardous pharmaceutical waste. And that means waste generators should take increased care in how they manage their hazardous waste.

Here are some tips for managing your hazardous waste pharmaceuticals:

  • Minimize hazardous waste generation as much as possible.
  • Properly segregate waste.
  • Plan for adequate storage for both existing and anticipated hazardous waste.
  • Incorporate additional time into planning for off-site transportation.
  • Work with regulatory agencies to secure storage extensions.
  • Consult with a trusted healthcare waste services provider.

What if I Accidentally Mix Pharmaceutical Waste Streams?

If you or someone else accidentally mixes non-hazardous pharmaceutical waste with hazardous pharma waste, the entire mixture must be managed as hazardous waste. The non-hazardous waste has become contaminated and must be treated and disposed of as hazardous waste. This will include labeling the containers properly, storing the waste in a secure area, and disposing of the waste in accordance with RCRA and local regulations. Hazardous waste disposal guidelines are more stringent and will require more time from your staff to execute and make sure all regulations are followed.

Obviously, with the incineration backlog discussed above, you want to make sure you keep your non-hazardous waste separate to avoid adding to storage issues. If you have questions about managing mixed pharmaceutical waste, consult with a qualified medical waste disposal company.

TriHaz Solutions can provide guidance on how to properly manage all your pharmaceutical waste and can help you navigate regulations and adhere to proper procedures through challenging times. Contact us today if you have questions about managing your non-creditable hazardous pharmaceutical waste.  

*NOTE: The EPA finalized new management standards for hazardous waste pharmaceuticals in 2019 to simplify and streamline regulations that were more industry oriented. Instead of managing pharma waste under the RCRA hazardous waste generator regulations, healthcare facilities (and reverse distributors) manage their waste under 40 CFR part 266, subpart P. There are several benefits to this tailored approach, such as not having to specify hazardous waste codes on manifests and being able to accumulate hazardous waste pharmaceuticals on site, without a RCRA permit, for up to one year. However, after publication of the final rule, the incineration backlog developed, making those accumulation limits difficult, if not unattainable. EPA’s memorandum about options to address the backlog does not address this time limitation for Small Quantity Generators (SQGs) and Large Quantity Generators (LQGs) generating non-creditable hazardous waste pharmaceuticals.(They may request and receive extensions for hazardous waste that is not pharmaceuticals.)

Learn more about Very Small Quantity Generators (VSQGs) and and Subpart P.


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