Is Nitroglycerin Hazardous Waste?

It’s easy to get confused about the proper disposal of medicinal nitroglycerin due to the categorization of the drug. By definition, nitroglycerin is listed specifically as hazardous waste under the EPA Resource Conservation and Recovery Act (RCRA). It is further categorized as P-listed (P081) or Acutely Toxic. But there is some good news regarding the proper disposal of medicinal nitroglycerin. The EPA has classified most if not all of the nitroglycerin used in healthcare settings as non-hazardous. In fact, in 2003 the EPA issued a guidance letter to clear up the hazardous waste listing for this product. The response confirmed under the revised mixture and derived-from rules [40 CFR 261.3(g)(1)], which went into effect February 1, 2002, that a waste that has been listed solely for the characteristic of ignitability, corrosivity or reactivity is not regulated as a hazardous waste if it does not exhibit any hazardous waste characteristic. Moreover, if the waste does not exhibit a characteristic at the point of generation, it is considered to have never been a hazardous waste and does not need to meet land disposal restrictions (LDRs) (66 FR 27286, May 16, 2001). The EPA determined that the scope of the P081 listing does not include medicinal forms of nitroglycerin. Until this clarification, nitroglycerin was classified and handled as RCRA hazardous waste. The new rules took immediate effect in states that have not been authorized to carry out the base hazardous waste program. However, because the revised mixture and derived-from rules are less stringent than the existing federal requirements, states which are authorized for the base RCRA program are not required to adopt them [40 CFR 271.1(i)]. The regulatory authority in Arizona (ADEQ) has adopted the federal position. Since this clarification, best management practices dictate that nitroglycerin be handled as non-hazardous pharmaceutical waste and sent to a medical waste incinerator or municipal incinerator for treatment. Many medical waste disposal companies still advise their customers to treat nitroglycerin as a P-Listed RCRA waste. But this practice can be considerably more expensive given the more extensive manifesting and labeling requirements, not to mention the increase in final disposal costs. One other consideration is that any facility producing 1kg (2.2 lbs.) of P-listed waste in a calendar month is categorized by the EPA as a large quantity hazardous waste generator. Large quantity generators must follow additional requirements specific to proper management of waste, time and storage limits, training, preparedness and prevention, contingency plans, and reporting to regulatory agencies. These facilities must also pay increased fees to regulatory agencies. US Bio-Clean, an Arizona medical waste disposal company, provides professional guidance in the proper categorization, segregation and disposal of pharmaceutical waste, including nitroglycerin.

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