Microsoft word - p-list mgmt with new epi salts updated 2011.doc

P-Listed Chemicals and Empty Containers
Management and Disposal Guidelines

Hospitals, pharmacies, and other healthcare providers use a variety of products that contain
hazardous chemicals, including those that are considered acutely hazardous or P-listed chemicals
when they become “waste.” Unused or expired P-listed chemicals are managed under the New
Hampshire Hazardous Waste Rules
(Env-Wm 100-1100) if they are the sole active ingredient.
Healthcare facilities that generate over one kilogram or 2.2 pounds per month of P-listed wastes
are full quantity generators of hazardous waste in New Hampshire [Env-Wm 503.02 (a)] and
must adhere to stringent hazardous waste regulations (Env-Wm 509).
Containers and inner liners that have held acutely hazardous wastes (P-listed) are deemed empty
if the containers or inner liners have been triple rinsed with appropriate rinsate and no residue
can be removed from the container [Env-Wm 401.03(h)(3)]. The rinsate is considered a
hazardous waste mixture and must be managed accordingly. If the container is not rinsed out
prior to disposal, then the container and the contents must be managed as a hazardous waste.
Facilities cannot dispose of empty P-listed chemical containers that have not been properly
rinsed in the medical “red bag” waste or in the solid waste “trash.”
Healthcare facilities that use P-list chemicals should review current waste management
procedures and make appropriate changes in order to adhere to New Hampshire Hazardous
Waste Rules.
Examples of P-Listed Pharmaceutical Waste (The complete list of P-listed chemicals can be
found at Env-Wm 402.04.):

Epinephrine Salts
Any chemical or formulation where epinephrine salt is the sole active ingredient is not a P042
listed hazardous waste when discarded. Please be aware that a chemical or formulation
containing epinephrine salt can still be regulated as a hazardous waste if it exhibits a waste
characteristic under Env-Wm 403.
Management Example: Products with expired shelf lives
Occasionally, some products’ shelf lives expire. Facilities should:
1. Return the product to a distribution company or manufacturer through a “take-back” program. Review the facility’s group purchasing organization contract for further information. Some of these services are included in the contract. 2. Create an inventory control program to limit the amount of products that expire before use. Resources spent on the management of expired products are resources lost. 3. Example, when unused physostigmine is the sole-active ingredient, it must be managed as a hazardous waste. The waste code on the manifest should be P204. This amount will also count towards the hazardous waste generation status.
Management Example: Nitroglycerin Formulations
The Department of Environmental Services adopted a nitroglycerine formulation
exemption to the New Hampshire Hazardous Waste Rules. The exemption reads:
Nitroglycerine, listed as P081 [is exempt], provided that it: a. Was to be used for medicinal purposes; and b. Does not exhibit a hazardous waste characteristic as set forth in An explanation of the Characteristic Waste Rules Env-Hw 403 can be found on our website at Env-Hw 400 Identification & Listing of Hazardous Wastes Or a paper copy of the rules can be purchased by calling the Public
Pollution Prevention at Healthcare Facilities
Since 1998, the Department of Environmental Services New Hampshire Pollution Prevention
Program has undertaken a project promoting pollution prevention opportunities at healthcare
facilities. This on-going project involves providing on-site assistance at participating facilities,
setting up an infrastructure to promote continuous environmental improvement, and providing
outreach and training activities to New Hampshire healthcare facilities.
For further information on Pollution Prevention at Healthcare Facilities, contact Melissa Zych,
DES, at (800) 273-9469 or
For further information on the New Hampshire Hazardous Waste Rules, contact the Hazardous
Waste Compliance Section at 271-2942 or toll free at 866 - HAZWAST.
This document was paid for in part by a Pollution Prevention Incentives for States grant from U.S. EPA-New England to assist the healthcare sector.


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