Pharmaceutical Listed Waste

Pharmaceutical Listed Waste and Why it’s Dangerous

Pharmaceutical waste is one of the more complex categories of medical waste in terms of the regulations and procedures that govern its’ proper segregation and disposal. There is good reason for this, since pharmaceutical waste, particularly listed waste, has the potential to be very harmful to people, animals and the environment. Given these facts, it is clearly quite important for those who hold administrative positions in healthcare or pharmacy settings to be well-informed on the details of these waste streams. So here, we’ll go over the basics on pharmaceutical listed waste and why it’s dangerous.

pharmaceutical-listed-waste-3771What is pharmaceutical listed waste?

Pharmaceutical listed waste is a term used to describe pharmaceutical waste products that are deemed hazardous waste by the Environmental protection Agency (EPA) and have also been placed on one of the hazardous waste lists created by the Resource Conservation and Recovery Act (RCRA). The most common listed pharmaceutical wastes generated by healthcare facilities and pharmacies will be P-listed or U-listed.

About P-listed pharmaceutical waste

According to the Healthcare Environmental Resource Center (HERC), P-listed wastes are “acutely toxic,” a term used to describe substances that can cause death or irreversible illness at low doses. A number of pharmaceuticals are found on the RCRA P-list. These are products in which the sole active ingredient is a P-listed substance, and which have not been used for their intended purpose, becoming waste. This may include expired or unused medications, for instance,or partially used products. Devices, like syringes, used to dispense these products must also be treated as P-listed waste. Containers that held P-listed pharmaceuticals are also considered to be P-listed waste, unless they have been triple-rinsed in compliance with RCRA regulations, as are some packaging materials associated with P-listed drugs. Examples of common P-listed waste products found in the healthcare or pharmacy setting include:

  • Warfarin or Coumadin
  • Phentermine
  • Physostigmine
  • Arsenic Trioxide

These examples are just a few of the substances commonly handled by pharmacies and healthcare facilities that appear on the P-list. According to HERC, that list contains 239 acutely toxic substances, and 15 of them may be expected to be found in the pharmacy/healthcare setting.

About U-listed pharmaceutical waste

U-listed pharmaceutical waste, according to HERC, is waste that is toxic, and still must be treated as hazardous waste, but is not as dangerous as P-listed substances. To be deemed a U-listed pharmaceutical, a drug must contain a U-listed substance as its sole active ingredient and, as with P-listed drugs, must not have been used for its intended purpose, making it a waste product. Containers that held U-listed pharmaceuticals or devices used to administer them may also be considered hazardous waste under some circumstances. U-listed waste products commonly found in pharmacy and healthcare settings include:

  • Mitomycin
  • Formaldehyde
  • Lindane
  • Selenium sulfide
  • Azaserine
  • Acetone

According to HERC, there are 472 materials included on the RCRA U-list, and 66 of these are commonly handled in the pharmacy/healthcare setting.

While P-listed and U-listed pharmaceutical waste streams may be the most heavily regulated and hazardous ones you’ll deal with, there are other waste streams that also must be handled with care. D or F-listed substances can also be a concern in the pharmacy or healthcare setting, although they may not always be identified as pharmaceutical waste. This may include solvents, disinfectants and other cleaning solutions that may be considered hazardous waste under RCRA regulations.

Keeping tabs on all substances that pass through your facility and determining whether or not they are listed waste products is a complex process. Quite often, the most practical means of ensuring that hazardous waste products are handled in a safe manner and in compliance with RCRA regulations is to partner with a solid, full-service medical/pharmaceutical waste services company.


Simplify your job and stay up-to-date on medical and hazardous waste compliance for healthcare and industry.

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