New rules for pharmaceutical waste


New rules went into effect on October 31, 2020, for the management of dangerous waste pharmaceuticals, which set new requirements for Washington state health care facilities that generate pharmaceutical waste.

Under the new rules, all pharmaceutical waste containers must now have a label that reads “Hazardous Waste Pharmaceuticals.” The new rules do not allow the use of “hazardous waste” and “pharmaceutical hazardous waste” on waste container labels. If you have pharmaceutical waste containers currently in use that aren’t labeled with “Hazardous Waste Pharmaceuticals,” edit the existing label to reflect the new label requirement.

  • EH&S will provide updated labels that comply with the new requirement to UW units that have routine collection requests containing pharmaceutical waste.
  • The UW Medicine medical centers and Harborview Medical Center Environmental Services are aware of the label requirement; all new containers they provide will reflect this change.

In addition to the new label requirement, if you ship your potentially creditable dangerous waste pharmaceuticals directly back to a reverse distributor (instead of sending them to UW Pharmacy), you are now required to do the following:

  • Verify that your reverse distributor has an active EPA/State ID Number and is regulated under RCRA subpart P or equivalent state dangerous waste pharmaceuticals regulations.
  • Confirm delivery of the potentially creditable dangerous waste pharmaceuticals shipment within 35 calendar days of shipment.
  • Keep paper or electronic records for each shipment for at least five years from the date of shipment.

The new rules apply if your unit:

  • Provides preventative, diagnostic, therapeutic, rehabilitative, or palliative care to improve the physical or mental condition of humans and/or animals, or
  • Sells or distributes pharmaceuticals

Visit the Washington State Department of Ecology Managing Pharmaceutical Waste webpage for additional details about the new pharmaceutical waste regulations.

Contact the EH&S Environmental Programs office at 206.616.5835 with questions about pharmaceutical waste.