Management of Household Pharmaceuticals Collected by Law Enforcement During Take-Back Events and Programs Memo
This memorandum provides law enforcement agencies with information on how to more cost effectively manage household pharmaceuticals collected in take-back programs. Specifically, the memorandum describes the various options law enforcement agencies can use to transport and destroy household pharmaceuticals collected in take-back programs consistent with the applicable regulations under EPA, Drug Enforcement Administration (DEA), Department of Transportation (DOT), and U.S. Postal Service (USPS).
In the memorandum, EPA clarified that law enforcement agencies should NOT use “burn barrels” or any other uncontrolled open burning method or technology to destroy household pharmaceuticals collected during take-back events or in take-back kiosks.
EPA also clarified that law enforcement agencies are not required to drive collected household pharmaceuticals to a combustion facility. The collected pharmaceuticals can be sent for destruction via common carrier (in accordance with DEA and DOT or USPS procedures) for destruction at:
- Hazardous waste combustors
- Large and small municipal waste combustors (MWCs)
- Hospital, medical, and infectious waste incinerators (HMIWIs)
- Commercial and industrial solid waste incinerators (CISWIs), and
- Very small municipal waste combustors that are regulated as other solid waste incinerators (OSWIs).
EPA recommends that the collected household pharmaceuticals be sent to a permitted hazardous waste combustor as this is the most protective approach, but the other types of combustors listed above are also allowed. For additional information, check out EPA's recommendation for incinerating pharmaceuticals from take-back events* (PDF) (9 pp, 1.6 MB, About PDF).
Click here for a map of the locations of the various types of allowable commercial waste combustors. When law enforcement agencies use common carriers to send their collected household pharmaceuticals for destruction, they may ship it to any DEA-registered reverse distributor. However, if a combustor is nearby, it may be more cost effective for law enforcement to drive the collected household pharmaceuticals to a combustor and witness the destruction. The map is intended for law enforcement agencies to determine whether it is feasible to drive collected household pharmaceuticals to a commercial waste combustor versus simply shipping the collected household pharmaceuticals to a DEA-registered reverse distributor.