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Washington State Dental Association

Pharmaceutical Waste Regulations

Waste management can be very complex and raise many questions as to how a dental practice should properly dispose of certain materials. When determining which disposal services are necessary for your practice, it is important to differentiate between what is a vendor policy and what is an actual state or federal regulation. 

The United States Environment Protection Agency (EPA) is currently in the process of updating the federal rules relating to pharmaceutical waste management. The Washington State Department of Ecology (Ecology) is delegated by the EPA to enforce the Resource Conservation and Recovery Act (RCRA) which regulates all solid and hazardous waste in Washington state. This authority gives Ecology the ability to self-regulate all solid and hazardous waste so long as their requirements are at least as stringent as those established by the EPA. 

As a result, once the new EPA pharmaceutical waste management regulations take effect, there will be no immediate impact on providers in Washington state. As a delegated RCRA entity, Ecology must administer its own stakeholdering process at the state level before approving any new rule changes. Any changes to the federal rules will likely trigger a mandated change in the Ecology rules; however, this could take several months to implement. 

Ecology has several resources available to providers regarding waste regulation in Washington state. An Interim Enforcement Policy for Pharmaceutical Waste in Healthcare was released back in 2008. Within its enforcement discretion, Ecology will refrain from enforcing portions of the Dangerous Waste Regulations (WAC 173-303) at facilities meeting the conditions of this policy. Ecology has also released a Guide for Dangerous Pharmaceutical Waste Generators in Washington State which provides a summary of requirements for managing pharmaceutical waste.

It is important to note that dental offices are responsible for evaluating the types of wastes generated and dispose of this waste properly. According to the EPA, the proper waste identification process involves determination of:

  • Whether the waste is a “solid waste,”
  • If the waste is specifically excluded from the RCRA regulations,
  • If the waste is a “listed” hazardous waste, and 
  • If the waste exhibits a characteristic of hazardous waste. 

Should you have additional questions regarding pharmaceutical disposal procedures for your practice, please contact the Washington State Department of Ecology at 360-407-6000. 

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