Frequently Asked Questions
I am in a state that has adopted Subpart P. Can I send my potentially creditable HWP's to a RD in a state that has not year adopted Subpart P?
YES - As long as the RD is providing you with the required documentation that you need for your recordkeeping compliance. Examples include: notification of shipment receipt and unauthorized waste reports. IMPORTANT - Verify with the RD that they issue unauthorized waste reports. This is rare unless they are in a state that has adopted Subpart P.
Which RD's are in states that have adopted Subpart P?
What is the most cost effective way to dispose of my non-creditable HWP's?
Contact PTI to discuss options.
Can I send any OTC (non-prescription) HWP's back to the RD for credit?
YES - If they meet the definition of PCHWP. NO - If they meet the definition of NCHWP.
Is there a difference between NIOSH hazardous drugs and EPA hazardous drugs?
YES - NIOSH hazardous drugs pertain to USP<800> regulations and EPA hazardous drugs fall under Subpart P. Do not combine or confuse the two. .
Can I throw my empty warfarin bottles in the garbage now?
YES - if your facility has adopted Subpart P and your state does not restrict it. NO - if you state has not adopted Subpart P.
Can I handle my nicotine as non-hazardous waste?
YES - If your state has adopted this amendment and the nicotine is in the form of patches, gums or lozenges.
Which drugs are EPA hazardous waste?
Contact PTI or one of their resellers to discuss waste characterization options..
Do I have to follow Subpart P?
NO - Subpart P is optional if you are a VSQG (Very Small Quantity Generator). However, you must be able to demonstrate this to a regulator.
We use a 3rd party disposal device for our DEA controlled substance disposal. Can we place those in the regular trash after use?
NO – not if any of the drugs contained in the device are hazardous. DEA Controlled examples may include but are not limited to: chloral hydrate, diazepam solutions, testosterone gels + more. This also applies to non-DEA controlled substances as well. Also, more states are starting to restrict any pharmaceuticals from entering the landfill.
Do you offer assistance with Subpart P compliance through consultation or presentations?
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