On August 21, 2019, EPA’s Final Management Standards for Hazardous Waste Pharmaceuticals takes effect federally.  The sewer ban component of the new rule applies in all states.  Healthcare facilities are now prohibited from flushing hazardous waste pharmaceuticals, including DEA controlled substances and “pharmaceutical wastage” that are hazardous waste.  This sewering ban may drive many facilities to stop flushing pharmaceuticals entirely (even those that are not hazardous waste), given how complicated it is in practice for healthcare provides to determine which drugs are hazardous waste and cannot be flushed.

The Subpart P management standards also applies in non-authorized states, Alaska and Iowa, Puerto Rico, as well as early adopters, such as Florida, New Jersey and Pennsylvania, that are incorporating the new regulations by reference.  Healthcare facilities will need to pay close attention to the rules that apply in the state of waste generation, as well as the states where they send their hazardous waste pharmaceuticals for reverse distribution or disposal.   State implementation may remain in flux until July 1, 2022, the final deadline for state adoption.

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