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Frequent Questions for Pharmaceutical Collection Events/Programs

Background

The semi-annual National Take-Back Day events are part of an initiative of the U.S. Drug Enforcement Administration (DEA) in coordination with state and local law enforcement agencies. This initiative has launched several nationwide events over the past few years to provide the public opportunities to safely dispose of expired, unwanted, or unused pharmaceuticals found in their homes. Other organizations also sponsor pharmaceutical take back events and municipalities may accept pharmaceuticals as part of their household hazardous waste collection efforts. Some law enforcement agencies may also have collection bins available for the public to drop off their unwanted pharmaceuticals. For information about how EPA regulates expired, unwanted, or unused pharmaceuticals from households in conjunction with take-back events/programs, see below.

Frequent Questions

  1. Can hospitals, pharmacies, or any other business generating pharmaceutical waste use take-back programs to dispose of expired, unwanted or unused pharmaceuticals?
  2. How will the pharmaceuticals collected during these events be disposed of?
  3. But aren’t some pharmaceutical wastes hazardous waste?
  4. Why doesn’t EPA require that collected household hazardous pharmaceutical wastes be disposed of as hazardous waste?
  5. EPA encourages recycling, so can I donate my unused medications to charity? Can I return them to a pharmacy or my doctor’s office?
  6. I am unable to participate in the National Take-Back Day event, and there are no other take-back events in my area. How should I dispose of my pharmaceuticals?

Question 1:
Can hospitals, pharmacies, or any other business generating pharmaceutical waste use take-back programs to dispose of expired, unwanted or unused pharmaceuticals?

Answer: Generally no. The National Take-Back Day, as well as other pharmaceutical take-back collection events that are held across the United States, are usually organized to provide an opportunity for the members of the public to safely remove and dispose of expired, unwanted or unused pharmaceuticals from their homes. Public collection events are generally not intended to manage waste from businesses or designed to comply with the regulations applicable to business waste. Healthcare facilities or any other healthcare-related business that generate pharmaceutical wastes are responsible for appropriately managing their wastes in accordance with all local, state and federal environmental regulations.

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Question 2:
How will the pharmaceuticals collected during these events be disposed of?

Answer: Household wastes, including pharmaceuticals found in homes, are generally considered municipal solid waste. The management and disposal of municipal solid waste is regulated by local and state environmental agencies rather than at the federal level. Depending on state and local requirements, organizers of take-back events typically dispose of the collected pharmaceuticals at permitted municipal solid waste incinerators or permitted hazardous waste incinerators. In addition, organizers of collection events should contact the local and state environmental regulatory agency to ensure that the collected hazardous pharmaceutical wastes are managed in accordance with all local and state environmental regulations. However, EPA generally recommends that collected household hazardous wastes be managed and disposed of as hazardous wastes.

See: EPA's Recommendation for Incinerating Pharmaceuticals from Take-Back Events (9 pp, 1.5 MB, about PDF)

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Question 3:
But aren’t some pharmaceutical wastes hazardous waste?

Answer: Under the federal Resource Conservation and Recovery Act (RCRA) hazardous waste management regulations, a very small percentage of pharmaceuticals on the market are considered hazardous waste when they are disposed of. In addition, some state environmental regulatory agencies regulate additional pharmaceutical wastes as hazardous that may not be regulated by EPA. A waste is considered hazardous if it is either specifically listed as a hazardous waste by EPA or the waste exhibits a characteristic of a hazardous waste (EPA’s four characteristics of a hazardous waste are ignitability, corrosivity, reactivity and toxicity). The regulations applicable to hazardous waste pharmaceuticals being disposed of depend on the type of generator of the waste and the way the waste is managed.

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Question 4:
Why doesn’t EPA require that collected household hazardous pharmaceutical wastes be disposed of as hazardous waste?

Answer: The federal RCRA hazardous waste management regulations include an exemption for all waste generated by individuals in homes and residences; however, not all states recognize this exemption once household hazardous wastes are collected and consolidated. When Congress enacted RCRA in the 1970s, it indicated that the hazardous waste regulations should not apply to households. Thus, under the “household hazardous waste” exemption (40 CFR 261.4(b)(1)), pharmaceutical wastes generated by households are not required to be managed in accordance with the federal hazardous waste regulations, even when collected at a take-back event. Although EPA does not regulate household wastes, we recommend that collected household hazardous wastes be managed and disposed of as hazardous wastes. Organizers of collection events should contact the local and state environmental regulatory agency to ensure that the collected hazardous pharmaceutical wastes are managed in accordance with all local and state environmental regulations.

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Question 5:
EPA encourages recycling, so can I donate my unused medications to charity? Can I return them to a pharmacy or my doctor’s office?

Answer: No, if the unused medication is a listed as a controlled substance by DEA. It is illegal under the Controlled Substances Act (CSA) for consumers to give their pharmaceuticals that are controlled substances to someone else, including charitable organizations, pharmacists or physicians. See list of controlled substances (PDF) (11 pp, 59K, About PDF). However, DEA is currently working on new regulations to provide consumers various options for disposal of controlled substances potentially including take-back programs.

In regards to unused medications that are not controlled substances, donation to charitable organizations is generally not advisable due to possible reductions in potency of pharmaceuticals due to improper storage and/or mishandling, as well as concerns over intentional adulteration of pharmaceuticals. However, some states do allow the transfer of unused pharmaceuticals through state repository programs with requirements designed to address these concerns (e.g., the pharmaceutical is not a controlled substance, has been properly maintained with the tamper-proof packaging undisturbed, and the expiration date is beyond six months at the time of donation). More information about state repository programs and their restrictions Exit EPA. Some pharmacies have collection capabilities such as mailers to send pharmaceuticals for disposal or a collection bin. EPA recommends that consumers utilize these methods for pharmaceutical disposal where available.

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Question 6:
I am unable to participate in the National Take-Back Day event, and there are no other take-back events in my area. How should I dispose of my pharmaceuticals?

Answer: EPA always encourages the public to take advantage of pharmaceutical take-back programs or household hazardous waste collection programs that accept pharmaceuticals, as these programs offer a safe and environmentally-conscious way to dispose of unwanted pharmaceuticals. If there are none available to you, please contact your local and state waste management authorities for guidance on discarding any unwanted pharmaceuticals. For more information please refer to the Food and Drug Administration's guidance: Disposal of Unused Medicines: What You Should Know.

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