Regulatory Brief

 Disposal of Hazardous Pharmaceutical Wastes

Formal title: 40 CFR Part 260, 261, 264, 265, 268, 270 and 273; Docket Number [EPA-HQ-RCRA-2007-0932; FRL-8746-2] Amendment to the Universal Waste Rule: Addition of Pharmaceuticals

The Environmental Protection Agency (EPA) proposes to amend to the Universal Waste Rule to include the addition of hazardous pharmaceutical wastes.

Brief Description and AVMA Response:

The Environmental Protection Agency (EPA) is proposing to add hazardous pharmaceutical wastes to the Universal Waste Rule. This proposed rule would facilitate better management of pharmaceutical wastes by streamlining the generator requirements and encouraging generators of hazardous pharmaceutical wastes to manage them under the provisions of the Universal Waste Rule. Under this proposal, depending on state rules, facilities may choose to continue managing these hazardous wastes under the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations, or they may opt to manage hazardous pharmaceutical wastes as "universal wastes."

The AVMA applauds the EPA's continued leadership in protecting the environment and appreciated the EPA's initiative to seek new ways in which handlers of pharmaceuticals may dispose of pharmaceutical waste in a manner that is safe for the public health, including the health of the environment. Specifically, while the veterinary profession is a minimal contributor of hazardous pharmaceutical waste due to practices such as tight inventory control and transfer of unused pharmaceuticals back to distributors, the AVMA appreciates the EPA's initiative to provide an additional option for disposal of hazardous pharmaceuticals, allowing the disposal of pharmaceutical waste under either EPA's "Universal Waste" regulations (if finalized) or under the current RCRA regulations.

Background Documents:

View AVMA's response to the EPA (PDF)

View Federal Register document (PDF)


AVMA responded on December 31, 2008