Among their many other critical duties, pharmacy staff are tasked with safely disposing of hazardous waste materials, including certain substances and drugs defined at the federal level. However, the many classifications and stipulations can make it difficult to track exactly what your liability is.
Is your pharmacy a Conditionally Exempt Small Quantity Generator (CESQG)?
If your independent, retail or hospital pharmacy generates no more than 220 lbs (100 kg) of hazardous waste per month, then per the EPA you are a Conditionally Exempt Small Quantity Generator (CESQG). This means that–so long as you comply with other basic requirements—you are exempt from the full hazardous waste regulations that apply to generators of larger waste quantities.
You can maintain your exemption by making sure you meet three specific waste management requirements:
Some examples of a Treatment, Storage, and Disposal Facility approved by the EPA include:
It’s recommended that you call the appropriate state agency to verify that the TSDF you’ve selected has any necessary permits.
For more on other compliance considerations, download our Compliance Handbook.