Publication Number SQG-RR-6(11/02) rev. 4/03 

April 2003 

Final Report 

Pharmaceutical 

Waste Survey 

Debra Oliver 

Local Hazardous Waste Management Program in King County 

Interagency Resource for Achieving Cooperation 

Pharmaceutical Workgroup 

Alice I. Chapman, P.E. 

Local Hazardous Waste Management Program in King County 

Interagency Resource for Achieving Cooperation 

Pharmaceutical Workgroup 
This report was prepared by the Local Hazardous Waste Management Program in King 

County, Washington. The program seeks to reduce hazardous waste from households 

and small quantity generator businesses in King County by providing information and 

technical assistance to protect human health and the environment. 

For more information or to order additional copies of this report contact: 

130 Nickerson Street, Suite 100 

Seattle, WA 98109 

206-263-3050 TTY Relay: 711 

Fax 206-263-3070 

www.govlink.org/hazwaste/

Publication Number SQG-RR-6(11/02) rev. 4/03 

Oliver, Debra and Chapman, Alice. Pharmaceutical Waste Survey, Final Report. Seattle, WA: 

Local Hazardous Waste Management Program in King County, 2003. 

Alternate Formats Available 

Voice: 206-263-3050 or TTY Relay: 711

PharmaceuticalWasteSurvey.doc Printed on Recycled Paper 
 

King County – Pharmaceutical Waste Survey i 

CONTENTS 

Acknowledgements ..............................................................................................................................................................1 

Introduction and Objectives ................................................................................................................................................2 

Survey Objectives...........................................................................................................................................................2 

Survey Data Limitations..................................................................................................................................................3 

Methodology..........................................................................................................................................................................4 

Findings.................................................................................................................................................................................5 

Who was Surveyed?.......................................................................................................................................................5 

Nature of the Waste and Quantity Information ...............................................................................................................7 

Quantity Data by Wastestream...............................................................................................................................7 

Physical State.......................................................................................................................................................10 

Active Ingredient Data ..........................................................................................................................................13 

Current Management Practices....................................................................................................................................14 

Process Flow Diagrams........................................................................................................................................14 

Disposal of Drug Wastes ......................................................................................................................................14 

Qualitative Data on Disposal Methods .................................................................................................................15 

Confusing Concepts: Hazardous, Biohazardous and Reverse Distributors .........................................................15

Awareness of Federal Hazardous Waste Regulations .................................................................................................16 

Preferred Waste Management Options ........................................................................................................................17 

Other General Considerations......................................................................................................................................18 

Summary and Conclusions................................................................................................................................................19 

Appendix A Survey Form..................................................................................................................................................23 

Appendix B Survey Protocol ............................................................................................................................................29 

Project...........................................................................................................................................................................31 

Background...................................................................................................................................................................31 

For your information only..............................................................................................................................................31 

Suggestion for an Opening ...........................................................................................................................................32 

Differences between medical industry and other industries we have visited:...............................................................32 

Vocabulary/Jargon........................................................................................................................................................32 

Survey form info............................................................................................................................................................33 

Special Information in Doctors’ Offices Regarding Samples: .......................................................................................34 

Appendix C Survey Plan and Considerations.................................................................................................................35 

Appendix D Process Flow Diagrams by Business Type................................................................................................39 

Appendix E Waste Quantity Data by Business Type .....................................................................................................51 

Appendix F Where are Drug Wastes Disposed? ............................................................................................................67 

Bibliography........................................................................................................................................................................89 
ii King County – Pharmaceutical Waste Survey 

Tables 

Table 1. Total Surveys Completed ...............................................................................................5 

Table 2. Incomplete Surveys from Randomly Generated List .....................................................5 

Table 3. Completed Surveys, by Business Type ..........................................................................6 

Table 4. Waste Category Descriptions .........................................................................................7

Table 5. Annual Quantity Generated by Business Type...............................................................8 

Table 6. Waste Categories by Business Type...............................................................................9 

Table 7. Physical State of Single-Phased Waste Streams...........................................................10 

Table 8. Waste Categories and Quantity Generated...................................................................11 

Table 9. Disposition of Wastes by Category and Quantities Disposed ......................................12 

Table 10. Drug Active Ingredient Data ........................................................................................13

Table 11. Disposition of Wastes and Quantities Disposed Per Year............................................14 

Table 12. Knowledge of RCRA Regulations ...............................................................................16 

Table 13. Maintain Records on Waste Pharmaceuticals ..............................................................17 

Table 14. Drug Waste Disposal Options That Would Work Best for Facility .............................18 

Table 15. Extrapolation of Waste Generated Statewide...............................................................20 

Table 16. Patient Contact per Day per Business Type .................................................................21 

Table 17. Average Quantity of Waste per Business.....................................................................22 
 

King County - Pharmaceutical Waste Survey 1 

ACKNOWLEDGEMENTS 

The information offered in this report is due to the combined efforts of many people. 

Thanks to the following for developing the study, questionnaire, data analysis and report: 

Alice Chapman, Technical Assistance Pollution Prevention team, Local Hazardous Waste 

Management Program in King County; Cheri Grasso, On-Site Consultation team, Local 

Hazardous Waste Management Program in King County; Stan Jeppesen,Washington 

Department of Health Board of Pharmacy; and Debra Oliver, Interagency Regulatory 

Analysis Committee. Thanks also to Bill Rowe and Doug Gallucci, University of 

Washington data gatherers; Tom Georgianna, statistician, King County Environmental 

Lab; Brian Westra, librarian, Local Hazardous Waste Management Program in King 

County; Sue Hamilton, Lisa Niehaus, Ann Peacock and Emmanuel Rivera, field staff; 

and Gail Savina, editor, Local Hazardous Waste Management Program in King County. 

The Interagency Regulatory Analysis Committee, or IRAC, was formed to address issues 

of regulatory conflict and to improve coordination between regulatory agencies. It is a 

forum where the mutual concerns of different agencies or jurisdictions can be addressed. 

IRAC’s mission is “to create a more effective and efficient means of protecting public 

health and safety through coordination of regulatory agencies.” To learn more about 

IRAC or become a member, write us at 130 Nickerson St, #100, Seattle, WA 98109, call 

us at (206) 263-3087, or visit our website at http://www.govlink.org/irac/. 

IRAC Pharmaceutical Workgroup members include representatives of the Local 

Hazardous Waste Management Program in King County, King County Industrial Waste, 

Public Health – Seattle & King County, Spokane Regional Solid Waste System, 

Washington Board of Pharmacy, Washington Department of Ecology, Washington State 

Pharmacists Association, Washington State University, United States Drug Enforcement 

Administration, University of Washington, United States Environmental Protection 

Agency, and the following private and not-for-profit organizations: Alan B. Jones, PhD., 

Full Circle Environmental; Interpretive Consultations, Inc., PharmEcology Inc.; and P.S. 

Industries, Inc. 

Special thanks to the Washington Board of Pharmacy for their support in this research. 

And finally, thanks to the medical care facilities and doctor’s offices that assisted by 

providing data. 
 

2 King County - Pharmaceutical Waste Survey 

INTRODUCTION AND OBJECTIVES 

The IRAC Pharmaceutical Workgroup was established at the request of the Medical 

Industry Roundtable1 (MIRT) to examine existing regulations affecting the management 

of drug wastes. While several proposals were made to improve drug waste management 

practices and associated regulations, discussions were hampered by a lack of data about 

drug waste generation, current management practices and input from the regulated 

community about feasible options. A literature review [Chapman] located limited data on 

these issues, and the workgroup completed the following survey to address remaining 

data gaps. 

Survey Objectives 

1. Gather local (King County) data that can be extrapolated to Washington State drug 

waste generators. 

2. Gather data from a variety of potential drug waste generators. 

3. Characterize potentially hazardous drug wastes according to the following: 

• types of wastes and potentially useful descriptive categories 

• physical state (solid, liquid, etc.) 

• quantities generated and how often, and 

• progress of drug through the facility (from product to waste, using a process flow 

diagram). 

4. Gather data on current drug waste management practices, including disposition, 

collection containers, recordkeeping, and commercial disposal services. 

5. Measure awareness of the federal Resource Conservation Recovery Act. 

6. Gather data on generators’ preferred waste management options. 

 

1 See the MIRT web site http://dnr.metrokc.gov/swd/bizprog/waste_pre/medical.htm for more information 

about this roundtable. 
 

King County - Pharmaceutical Waste Survey 3 

Survey Data Limitations 

The survey was developed and conducted within a short timeframe (about one month) to 

meet a public comment period deadline. For this reason, schedule demands and survey 

completion were a higher priority in study design than statistically-based representative 

sampling, and survey results should be viewed as descriptive data about drug waste 

management by respondents rather than data that can be generalized beyond those 

surveyed. 

In survey development, we expected that surveyors would talk with nurses in hospital 

units, where we believed that most drug waste was generated. Because nursing staff are 

so short-handed and busy taking care of patients, interruptions by surveyors were 

typically not possible. Instead, we surveyed those people who had some time to spend 

answering questions, from office managers to doctors. Gathering data about drug waste 

quantity was the priority, and other questions were asked if time permitted. For this 

reason most surveys are incomplete. 

The records kept by most facilities do not allow for ready comparison to Washington’s 

Dangerous Waste Regulations (Chapter 173-303). Thus, much of the quantity data on 

drug wastes were estimates from those persons generating the wastes, rather than facility 

data. Larger generators, such as some hospitals, maintained drug waste records on a 

pharmaceutical computer system called Pyxis. This system provides the quantity of active 

ingredient, but not the total weight of the drug, including inert ingredients and packaging. 
 

4 King County - Pharmaceutical Waste Survey 

METHODOLOGY 

A survey form was developed, field tested at two sites and revised to meet study 

objectives (see Appendix A). Survey protocols (see Appendix B) were written and staff 

were trained on study objectives and protocols. Those data collected by the Board of 

Pharmacy were summarized in a spreadsheet rather than on the survey form because they 

focused primarily on drug waste quantities. 

Using North American Industry Classification System (NAICS) codes [United States], 

potential drug waste generators were identified. Because the commercial business list 

source [info USA] uses the Standard Industrial Classification (SIC) code system, the 

NAICS codes were converted to SIC codes [http://www.census.gov/epcd/ 

naics/NAICS63.htm]. The infoUSA, Board of Pharmacy data [Morrison], and 

Department of Social and Health Services (DSHS) license data were used to find the total 

number of businesses in King County and in Washington State within each classification. 

To determine the number of surveys needed in each classification, weightings were 

assigned to the classifications based on expected relative amounts of waste generated 

(compared to the other classifications), relative variability within the classification, and 

time constraints of the project. Appendix C provides the list of NAICS codes, number of 

each to survey, and other survey planning considerations. 

After all surveys were completed, the classifications were modified to better reflect the 

primary function of the sites within the classification. For example, the classification 

“specialty outpatient clinic with doctors’ offices” was changed to “specialty outpatient” 

to more accurately describe the activities at the site. 

Eighty-nine businesses were randomly selected from InfoUSA lists and Department of 

Social and Health Services license information. Research Randomizer (see 

http://www.randomizer.org/), an on-line calculator, was used to generate the random 

numbers. An additional 25 businesses were selected by the Board of Pharmacy. These 25 

were surveyed for quantity data only. 

In-person surveys were conducted at some businesses, especially major medical centers. 

Most surveys were conducted via telephone. Surveys took from 5-10 minutes up to half 

an hour to complete. Survey data were entered into a Microsoft Access database for 

analysis. 
 

King County - Pharmaceutical Waste Survey 5 

FINDINGS 

Who was Surveyed? 

Tables 1, 2 and 3 below provide summary information about the surveys conducted. 

Table 1. Total Surveys Completed 

Source of respondents Number 

Attempted 

Number Completed2

Field tests 2 2 

Randomly generated list 90 36 

Selected by Board of 

Pharmacy 

25 223

Total 117 60 

Table 2. Incomplete Surveys from Randomly Generated List 

Reason Incomplete Number 

Call not returned 16 

Incorrectly classified as non-hospital site. When found to be a hospital, site 

dropped (a sufficient number of hospitals had already been surveyed) 

10 

Share practice with previously surveyed site 9 

Failed to contact site 7 

No longer in business or phone disconnected 6 

Refused interview 5 

Outside King County 1 

Total 54 

 

2 Number completed includes partially complete surveys. 

3 One pharmacy surveyed collected drug wastes from 54 locations statewide. 
 

6 King County - Pharmaceutical Waste Survey 

Table 3. Completed Surveys, by Business Type 

SIC Code4 Business Type Comments Surveyed Est. # in 

WA 

8011 doctors office included general practitioners, pediatrics, 

family practice, psychiatry 

16 10,000 

8093 specialty outpatient included occupational health, drug & alcohol 

center, women’s clinic, cosmetic & plastic 

surgery, urology, cancer, oral surgery, 

cardiology 

12 see 

80115

0742 veterinary all were small animal vet clinics, 4 of 7 were 

the largest clinics in Washington 

7 13616

8062A ambulatory/surgical 

center 

excluded hospitals 6 50 

8062 hospital excluded ambulatory/surgical centers 5 110 

5912 pharmacy - retail one pharmacy surveyed collected drug 

wastes from 54 locations statewide 

5 1068 

8051 nursing/boarding home 4 900 

8043 podiatrist 2 see 

8011

RD reverse distributor manages legend drugs and DEA controlled 

substances 

1 1 

8092 dialysis center 1 see 

8011 

8721 other accounting billing center for diagnostic imaging 1 NA 

Total 60 

 

4 SIC Codes were modified slightly to meet study needs (see comments). 

5 Per Morrison, there are 10,000 practitioner offices/clinics in Washington, assumed to include doctors 

office, specialty outpatient, podiatrist and dialysis center. 

6 Per infoUSA there are 1361 small animal veterinary clinics in Washington. 
 

King County - Pharmaceutical Waste Survey 7 

Nature of the Waste and Quantity Information 

Quantity Data by Wastestream 

Waste stream names (as reported by survey respondents) were reviewed and standardized 

into fourteen waste categories. The categories and types of wastes included in each waste 

category are described in Table 4 below. 

Table 4. Waste Category Descriptions 

Waste Category Category Includes: 

chemotherapy debris/liquid IV bags, tubing, gloves, gowns and other debris with some 

chemotherapy drug residuals remaining; AND vials of expired or 

partially used chemotherapy drug concentrate 

chemotherapy IV liquid unused IV preparations (chemotherapy drug concentrate mixed 

with other fluids for IV administration); AND vials of expired or 

partially used chemotherapy drug concentrate 

cough syrup unusable cough syrup, expired cough syrup samples 

debris IV bags, tubing, gloves, gowns, plastic and other debris not 

associated with chemotherapy. 

disinfectant absorbed onto wipes, gauze, or surgical scrubs 

empty syringe used syringes with no residual liquids (excludes partial injections) 

inhaler expired or unusable inhalers 

injectable liquids DEA controlled substances, Ketamine/valium 99+%, fentanyl, 

demerol, versed, morphine, propofol, lidocaine, marcaine, 

antibiotics, hormones, anesthetics, diuretics, heparin, iron, vaccines 

and others. These may be expired or partial injection residuals. 

This category description overlaps narcotics and IV liquids. 

However, the quantities are not duplicated. 

IV liquids IV preparations other than chemotherapy. Includes some drugs 

(e.g., blood pressure regulators), but quantity is primarily 

hydrations, total parenteral nutrition, and normal saline solutions. 

Vials of leftover or expired drug concentrates also included. 

mercury thermometer broken thermometer 

Mixed used for wastestreams described as “all medications”, “all wastes” 

or listing multiple drug forms (pills, tablets, patches, liquids, 

ointments, etc.) 

Narcotics DEA controlled substances, including Class II 

Ointment outdated ointment samples 

Pills outdated samples of tablets or pills, packaged in bingo cards or in 

bottles, antibiotics, birth control pills, allergy pills, over-the-counter 

and prescription drugs; expired, unused, partial and full 
 

8 King County - Pharmaceutical Waste Survey 

A total of 121 pharmaceutical waste streams from 55 sites7 were identified. An additional 

five sites had no identified waste streams. Of these, two had no drugs on site, two were 

serviced by a pharmacy, and one respondent couldn’t provide accurate information about 

the site. Quantity data were recorded for 89 waste streams from 47 sites (see Table 5 

below). For more detail about specific waste streams, see Appendix E for a database 

report of survey data by business type. 

Table 5. Annual Quantity Generated by Business Type 

Business Type Waste 

measured in 

ml 

Waste 

measured 

in lbs 

Waste 

measured 

as pills 

Waste 

measured as 

items/other 

Total # 

waste 

streams 

generated 

Ambulatory/surgical 

center 

11,742 0 34 2,5008 8 

Dialysis center 5,475 0 0 0 1 

Doctor office9 15,801 0 06,758 0 26 

Hospital 12,565,908 1,953 0 0 11 

Nursing/boarding home 0 0 6,500 0 1 

Pharmacy – retail10 0 292 300 0 4 

Podiatrist 2,842 0 245 0 3 

Reverse distributor 0 1,733 0 0 4 

Specialty outpatient 12,546 0 80 11411 16 

Veterinary 4,218 4 6 212 15 

TOTALS 12,618,532 ml 3,982 lbs 13,923 pills 2,616 items 89 

Hospitals, ambulatory/surgical care centers, and specialty outpatient clinics were more 

likely than other facilities to administer intravenous (IV) fluids, and they generated 

higher amounts of liquid wastes. IV fluids that provide hydration or total parenteral 

nutrition (TPN) without an additional “drug” added may not designate as dangerous 

waste since they consist primarily of normal saline, vitamins and minerals, dextrose, 

amino acids or enzymes. They may also be acceptable for sewer disposal with 

authorization from publicly owned treatment works. 

Survey respondents often provided quantity data in units of “pills.” Pills are packaged in 

blister packs or bingo cards and sometimes in bottles. The pharmaceutical waste stream 

therefore contains much packaging not accounted for by this survey. 

 

7 For this section of the report, the pharmacy that collects waste from 54 sites is counted as one site. 

8Includes empty syringes generated during flu season. 

9 6757 ml of this quantity is cough syrup. 

10 One pharmacy surveyed collected drug wastes from 54 pharmacies statewide, but is counted as one 

waste stream. 

11 Debris (intravenous tubing, syringes or gloves) 

12 Broken mercury thermometers 
 

King County - Pharmaceutical Waste Survey 9 

In a separate study, the University of Washington Environmental Health Services 

conducted a box survey13 of a cubic yard bin (650 pounds – converts to 3.2 

pounds/gallon) of waste pharmaceuticals after controlled substances and items for reverse 

distributors were removed. The box typically takes three to five weeks to fill. The 

following packaging information was recorded: 

Volume: 37% by volume was pills and bottles of liquids 

 63% by volume was packaging (not bottles) 

Weight: 72% by weight was pills and bottles of liquids 

 28% by weight was packaging (not bottles) 

Table 6 below identifies the types of businesses generating each category of waste and 

the amount of waste generated. Blank lines indicate those waste streams lacking quantity 

data. 

Table 6. Waste Categories by Business Type 

Waste Category 

Ambulatory / 

surgical 

center 

Dialysis 

center 

Doctors 

office 

Hospital 

Nursing or 

boarding 

home 

Pharmacy – 

retail 

Podiatrist 

Reverse 

distributor 

Specialty 

outpatient 

Veterinary 

Total # of Waste 

Streams 

Generated14

10 2 30 22 1 6 4 4 21 20 

Chemotherapy 

debris/liquid 

 1,873 lbs 

1 NoQty 

 4 NoQty 

Chemotherapy IV 

liquid 

 1,968,408 ml 

Cough syrup 6,757 ml 

Debris 1 NoQty 1 

NoQty 

96 ea 

Disinfectant 1 NoQty 4 lbs 

Empty syringe 2,500 ea 

Inhaler 100 ml 

Injectable liquids 11,612 ml 

2 NoQty 

5,475 ml 52 ml 18 ea 

12,392 ml 

1 NoQty 

4,218 ml 

IV liquids 10,597,500 ml 

3 NoQty 50 ml 

Mercury 

thermometers 

 2 ea 

Mixed 8,992 ml 1 NoQty 237 lbs 

Narcotics 130 ml 1 NoQty 0.2 lbs 

6 NoQty 

 1,496 lbs 4 ml 

1 NoQty 

Ointment 2,842 

ml 

 

Pills 34 ea 6,758 ea 

1 NoQty 

80 lbs 

2 NoQty 

6,500 

ea 

292 lbs15

300 ea 

1 NoQty 

245 ea 80 ea 

3 NoQty 

6 ea 

1 NoQty 

 

13 Bill Rowe, University of Washington Environmental Health and Safety Box Survey, reported in IRAC 

Pharmaceutical Workgroup meeting notes dated 10/22/2002. 

14 Although 121 waste streams were identified, no data was available pertaining to the waste stream 

generated by the accounting firm, surveyed because of its confusing SIC category. This waste stream was 

assumed not to be pharmaceutical in nature, so is not included in Table 6; therefore the total waste streams 

detailed in Table 6 is 120. 
 

10 King County - Pharmaceutical Waste Survey 

Physical State 

Physical state data was available for 118 waste streams and not available for three waste 

streams. Of the 118 waste streams, 100 (85%) were single-phased and 18 (15%) were 

multiphased. Multiphased wastes typically contained bags/tubing with residual liquids, 

ampoules/vials with residual liquids, syringes with residual liquids or liquids in vials 

mixed with oral solids/pills. The physical states of the single-phased waste streams are 

described in Table 7. 

Table 7. Physical State of Single-Phased Waste Streams 

Physical State # of Waste 

Streams 

Comments 

Liquid 48 primarily intravenous solutions or injectables 

Powder or pill 38 nearly all are pills 

Debris 12 IV tubing or bags, mercury thermometer 

Other - describe 1 empty syringe 

Ointment/lotion 1 podiatrist waste 

Total single-phased 

waste streams 

100 
 

King County - Pharmaceutical Waste Survey 11 

Table 8 below lists each waste category, the amount of waste generated for that category, 

and the number of waste streams surveyed in that category. Blank lines indicate the waste 

stream was not reported with those units. 

Table 8. Waste Categories and Quantity Generated 

Waste Category Units Reported 

lbs ml each 

# Waste 

Streams w/ 

Quantity Data 

# Waste 

Streams w/o 

Quantity Data 

Chemotherapy debris/liquid 

1,873 

 

3 5 

Chemotherapy IV liquid 1,968,408 1 

Cough syrup 6,757 3 

Debris 96 3 2 

Disinfectant 4 1 1 

Empty syringe 2,500 1 

Inhaler 100 1 

Injectable liquids 33,749 18 28 3 

IV liquids 10,597,550 5 3 

Mercury thermometers 2 1 

Mixed 237 8,992 4 1 

Narcotics 1,496 134 6 8 

No data 1 

Ointment 2,842 1 

Pills 37215 13,923 31 8 

TOTALS 3,982 lbs 12,618,532 ml 16,539 pills 

or items 

121 total waste streams 

Table 9 identifies the current disposal method for each category of waste, number of 

waste streams and amount disposed per category. Chemotherapy wastes were being 

disposed primarily through hazardous waste vendors, although some went to 

biohazardous waste containers. The “mixed” and “narcotic” wastes going to the 

hazardous waste vendor were reported by one reverse distributor. Otherwise, most drug 

wastes are going into the sewer system, into the garbage and into biohazardous waste 

containers.

 

15 One pharmacy surveyed collected drug wastes from 54 locations statewide, but is counted as one 

wastestream. 
 

12 King County - Pharmaceutical Waste Survey 

Table 9. Disposition of Wastes by Category and Quantities Disposed 

Disposition 

by 

Category 

Waste 

measured in 

lbs 

Waste 

measured in 

ml 

Pills counted 

individually 

Other waste 

measured as 

items 

Total # of 

waste streams 

reported 

# of waste 

streams not 

quantified 

BACK TO PHARMACY 

Cough syrup 340 1 

Injectable liquids 15 1 

Total to pharmacy 355 ml 2 

DOWN THE DRAIN 

Cough syrup 12 1 

Injectable liquids 11,581 11 1 

IV liquids 10,597,500 6 2 

Mixed 1,421 1 

Narcotics 130 3 1 

Pills 6,188 6 

Total down the drain 10,610,644 ml 6,188 pills 28 4 

HW VENDOR 

Chemotherapy debris/liquid 1,873 3 

Chemotherapy IV liquid 1,968,408 1 

Mixed 237 2 

Narcotics 1,496 2 

Total to HW vendor 3,606 lbs 1,968,408 ml 8 

ACCUMULATED IN COLLECTION BIN 

Pills 30 1 

Total accumulated 30 pills 1 

GARBAGE 

Chemotherapy 

debris/liquid 

 1 1 

Debris 36 1 

Disinfectant 4 2 1 

Narcotics 4 1 

Pills 36 93 5 

Total in garbage 40 lbs 4 ml 93 pills 36 items 10 2 

BIOHAZARD CONTAINER 

Chemotherapy 

debris/liquid 

 4 4 

Cough syrup 6,405 1 

Debris 60 4 2 

Empty syringe 2,500 1 

Injectable liquids 22,143 17 2 

Mercury 

thermometers 

 2 1 

Mixed 7,571 1 

Ointment 2,842 1 

Pills 80 517 8 2 

Total in biohazards 80 lbs 38,961 ml 517 pills 2,562 items 38 10 

NO DISPOSITION OR QUANTITY DATA PROVIDED BY GENERATORS 

IV liquids 1 1 

Narcotics 4 4 

No Data 1 1 

Total with no quantity 6 6 

OTHER CREATIVE METHODS 

Inhaler 100 1 

Injectable liquids 10 18 2 

IV liquids 50 1 

Narcotics 1 1 

Pills 595 12 2 

Total other methods 160 ml 595 pills 18 items 17 3 

REVERSE DISTRIBUTOR 

Mixed 1 1 

Narcotics 0.2 3 2 

Pills 256 6,500 7 4 

Total to reverse distributor 256 lbs 6,500 pills 11 7 

GRAND 

TOTALS: 

3,982 lbs 12,618,532 ml 13,923 pills 2,616 items 121 32 
 

King County - Pharmaceutical Waste Survey 13 

Active Ingredient Data 

Two sites, a hospital and an ambulatory/surgical center, used a computerized 

pharmaceutical tracking system called Pyxis. For drug products and wastes tracked on 

Pyxis, quantity data were limited to active ingredients. See Table 10 below. Pyxis does 

not track waste disposal. 

Table 10. Drug Active Ingredient Data 

Waste Description Active Ingredient 

Quantity Data 

Disposition Total Waste 

Quantity 

injectables fentanyl, demerol, versed, 

morphine - controlled 

substances; propofol, 

lidocaine, marcaine 

42 patients over 7 days, average 

205 patients/month, with (a very 

close estimate) 3117 mg active 

ingredients - calculates to 50 cc 

solution per week 

Down the 

drain 

2,600 ml 

Hydrations normal saline, dextrosebased solutions, not likely to 

designate as dangerous 

waste 

contact obtained data from Pyxis 

system, 189.3 liters over 13 

days 

Down the 

drain 

5,315,000 ml 

TPN total parenteral nutrition, 

patient receives nutrients 

through IV, may not 

designate as hazardous, 

contains amino acids, 

dextrose, enzymes, vitamins 

(K &C), potassium, calcium, 

sodium and saline solution 

contact compiled data from Pyxis 

computer system, 28.4 liters 

over 13 days 

Down the 

drain 

No data 

Narcotics - 

injectables 

DEA controlled substances contact checked Pyxis system 

for quantity data; 448 mg 

disposed 

No data No data 

Narcotics - 

solution 

based 

DEA controlled substances contact checked Pyxis system 

for quantity data; 15 mls 

disposed 

No data No data 

Narcotics - 

other misc. 

DEA controlled substances contact checked Pyxis system 

for quantity data; 1015 mgs 

disposed 

No data No data 

Narcotics - 

tabs/caps 

DEA controlled substances 

in solid tablets or caplets. 

contact compiled data from Pyxis 

computer system; 8765 mg 

active ingredient, timeframe? 

No data No data 
 

14 King County - Pharmaceutical Waste Survey 

Current Management Practices 

Process Flow Diagrams 

Process flow diagrams were completed for ten surveyed facilities. See Appendix D. 

Disposal of Drug Wastes 

About ten different methods were used to dispose of pharmaceutical wastes, including 

giving them to charitable organizations, putting them down the drain, using the reverse 

distribution process and disposing of them with biohazardous waste. 

Data on disposal were gathered for 115 of the 121 waste streams surveyed. Of these 115 

waste streams, 89 also had waste quantity data (summarized in Table 11 below), while 26 

did not have quantity data. (Of the 26 wastes without quantity data, four were put down 

the drain, two went in the garbage, ten went into the biohazardous waste container, seven 

went to a reverse distributor, and three were categorized as “other”.) 

Disposal methods categorized as “other” include giving wastes to charitable 

organizations, giving them to DEA-licensed vendors for incineration, returning them to 

the sales representative and putting them in the sharps container. 

For more detail about disposal of specific waste streams, see Appendix F. 

Table 11. Disposition of Wastes and Quantities Disposed Per Year 

Disposition 

(# Waste streams = 89) 

ml lbs pills each 

Accumulate and Wait (1) 30 

Biohazard Container (28) 38,961 80 517 2,562

Down the Drain (24) 10,610,644 6,188 

Garbage (8) 4 40 93 36

Hazardous Waste Vendor (8) 1,968,408 3,606 

Other (14) 160 595 18

Pharmacy (2) 355 

Reverse Distributor (4) 256 6,500 

Total (89) 12,618,532 3,982 13,923 2,616
 

King County - Pharmaceutical Waste Survey 15 

Qualitative Data on Disposal Methods 

Qualitative data on current disposal practices were gleaned from two open-ended 

questions: Do you have additional comments? and Do you have any other thoughts?

Several respondents donate expired pharmaceuticals to free clinics, missionary 

organizations, or directly to medical doctors working overseas. 

“Wasting Narcotics.” For respondents, the preferred (and by some considered the safest) 

way to destroy controlled substances and stay in compliance with Drug Enforcement 

Administration (DEA) regulations is by wasting them down the drain, that is, both 

destroying and disposing of them at once by putting them down the drain. (In one case 

the respondent injected leftover narcotics into dirty linens that would later be laundered). 

Of the thirteen respondents that had narcotics on site, methods varied for identifying and 

keeping these controlled substances separated from other drugs. Six respondents use only 

one or two narcotics regularly and were familiar with these drugs. Four keep narcotics in 

a locked box. Two respondents check their lists for which drugs are narcotics, and one 

facility labels syringes that contain narcotics. 

Vendors. In some cases vendors may be a source of misinformation and may add to a 

facility’s waste problems. In one facility, for example, the vendor routinely cleans out the 

sample closet, tossing all expired medications and ointments into the trash and replacing 

them with new samples. In another facility, staff – under the direction of a drug company 

representative – clean out the medicine cupboard quarterly, disposing of old antiinflammatories and antibiotics to the biohazard bag. Before receiving this instruction, 

staff had popped pills from blister packs and flushed them down the toilet. 

Containers for Drug Wastes. Respondents were asked three questions about storage of 

drug waste: Do you have containers for drug wastes? Where are they kept? How are they 

labeled? Of the 30 respondents, eighteen, or 60 percent, answered “yes” to having 

containers for drug wastes. Their containers were kept in a variety of places, including 

under the radiation table; in the x-ray process room, the store room, the pharmacy tech 

area, the IV prep room; in a locked box in the operating room; and in the lab area by the 

autoclave. Most were labeled “biohazardous;” one was labeled “expired.” One facility 

kept containers labeled “Schedule #” and “Waste Chemo.” 

Confusing Concepts: Hazardous, Biohazardous and Reverse Distributors 

Many respondents confused hazardous (some expired meds) with biohazardous 

(potentially infectious). For example, when asked about hazardous waste disposal for 

waste drugs, one associate hospital noted that a courier from the main facility picked up 

its full biohazardous waste containers on a daily basis. 

The term ‘reverse distributor’ is often understood to mean any vendor who picks up a 

waste from a health care facility. For example, one respondent who claimed to be using a 

reverse distributor actually put pharmaceuticals with the biohazardous waste and sent 
 

16 King County - Pharmaceutical Waste Survey 

them to Stericycle. Another respondent claiming to use a reverse distributor stated that 

they “collect drug waste for reverse distributor in the red bag.” 

Drug store chains and supermarket drug stores manage their pharmaceutical returns 

through their central office. One pharmacy stated they send even the dropped (and 

therefore unusable and not returnable) tablets back to their reverse distributor. 

Awareness of Federal Hazardous Waste Regulations 

Of the 33 respondents asked about federal Hazardous Waste regulations, 31 respondents 

– or 94 percent – stated that they did not have knowledge about the Resource 

Conservation and Recovery Act (RCRA), while two respondents stated that they knew 

about federal regulations. See Table 12 below. 

Table 12. Knowledge of RCRA Regulations 

Facility Description Knowledge of RCRA 

Regulations 

No knowledge of RCRA 

Regulations 

Ambulatory/ surgical center 

N = 3 

 3 

Doctors Office (includes 

podiatrist) N = 12 

 12 

Hospital N = 2 1 1 

Reverse Distributor N = 1 1 

Specialty Outpatient N = 9 9 

Veterinary N = 6 6 

Detailed logs are required by the Board of Pharmacy and Drug Enforcement 

Administration to account for the witnessed destruction of controlled substances. Of 34 

respondents asked about recordkeeping, 23 respondents, or two-thirds, stated that they 

kept no records of drug disposal and 11, or one-third, stated that they did keep records (in 

one case records were actually kept by the vendor). See Table 13 below. 
 

King County - Pharmaceutical Waste Survey 17 

Table 13. Maintain Records on Waste Pharmaceuticals 

Facility Description Maintain records on waste 

pharmaceuticals 

Do not maintain records on waste 

pharmaceuticals 

Ambulatory/ surgical center 

N = 4 

3 1 

Doctors Office (includes 

podiatrist) N = 10 

3 7 

Hospital N = 3 3 

Nursing/Boarding Home 

N = 1 

 1 

Reverse Distributor N = 1 1 

Specialty Outpatient N = 9 1 8 

Veterinary N = 6 6 

Preferred Waste Management Options 

29 respondents provided information about which waste management options they 

preferred. See Table 14 below. Eight respondents (27%) preferred to drop off drug waste 

at a pharmacy. Seven (25%) preferred to have a vendor pick up waste drugs. Seven 

(25%) preferred the reverse distributor choice. (Four of these were pharmacies, already 

serviced by reverse distributors.) Finally, six (20%) preferred using an associated 

hospital’s disposal service. 

The current practice of wasting controlled substances down the drain to comply with 

Drug Enforcement Administration regulations to prevent their abuse and diversion was 

the preferred option among those who employed it. Two options, drop-off at another site 

and a mail-away service, were not among the services chosen by any of the respondents. 

Another idea suggested by some respondents was to use an inventory control system to 

use up medications before they expire. And finally, several respondents complained of 

being over-regulated and felt that any collection and disposal of wastes – even to 

controlled combustion facility and without the designation process – is too much burden. 

One facility stated simply, “it must be convenient, cheap and easy.” 
 

18 King County - Pharmaceutical Waste Survey 

Table 14. Drug Waste Disposal Options That Would Work Best for Facility 

Service Requested Respondent 

associated hospital’s disposal service 6 doctors office -2 

specialty outpatient -4 

drop off drug waste at a pharmacy 8 ambulatory/surgical center -1

doctors office; outpatient -5 

nursing/boarding home-2 

other (What I’m doing now works.) 1 ambulatory/surgical center -1

reverse distributor 7 doctors office –1 

nursing/boarding home -1 

pharmacy – retail -4 

veterinary -1 

vendor pick-up at my site 7 doctors office -3 

hospital -1 

specialty outpatient -1 

pharmacy – retail -1 

veterinary -1 

other site drop-off 0

mail-away service 0

Total 29

Other General Considerations 

Respondents typically refer to biohazardous waste as “hazardous waste.” This led to 

confusion when discussing waste disposal and needs to be addressed when planning 

outreach efforts. 

Tracking systems in the health care industry are based on quantities of active ingredient 

in the drug; not total quantity of the drug (inert ingredients plus active ingredient). 

Medically trained staff are accustomed to handling even minutely infectious materials as 

biohazardous waste. They are also aware that chemotherapy drugs may have an adverse 

health effect at low concentrations and treat them with the utmost of care. It is 

conceivable that with this background, health care industry staff may tend to consider 

materials that may have only potentially contacted drugs to be hazardous wastes (as 

materials that have only potentially contacted anything infectious are considered 

biohazardous), unaware that there are thresholds and limitations. This needs to be 

addressed in outreach efforts. 

The reported quantities of most pharmaceutical wastes are small. Some of the largest 

numbers reported are IV fluids – typically nutritional substances such as TPN, saline, 

dextrose, etc. Unless some medications are added to IV fluids, the fluids are not expected 

to designate as Washington state-only dangerous waste. Removing IV fluids without 

drugs from this survey could reduce the totals even further. 
 

King County - Pharmaceutical Waste Survey 19 

SUMMARY AND CONCLUSIONS 

With a few exceptions (mostly large hospitals, pharmacies and those using chemotherapy 

drugs), the health care industry has been unaware of its responsibility to meet both 

federal and state hazardous waste regulations. Lacking clear guidance and proper disposal 

options, individuals within the industry have come up with a variety of creative methods 

to manage drug wastes. These include drains, bins, biohazard containers, trash cans, and 

linens. 

Outside of the regulation of controlled substances by the Drug Enforcement 

Administration, no checks exist in the system. Aware of the importance of preventing the 

diversion of narcotics and other controlled substances, the industry destroys them 

immediately (usually down the drain). There is similar awareness about the importance of 

managing biohazardous waste to prevent the spread of infection. These waste handling 

methods are often applied to waste pharmaceuticals as well, resulting in the improper 

management of both federal and state wastes. 

The health care industry itself, through the Medical Industry Roundtable, requested that 

the IRAC Pharmaceuticals Workgroup be formed to help find ways to manage a 

problematical waste stream. The survey found that some facilities were so concerned 

with the lack of waste management options that they simply stored up their wastes, 

waiting. 

The goal of the IRAC Pharmaceutical workgroup’s survey was to provide data to the 

Department of Ecology about the size and nature of pharmaceutical waste streams 

generated by the health care industry. Despite time limitations due to the public comment 

deadline and the lack of recorded waste disposal information available, a large amount of 

data has been collected and organized. 

Since the data were collected only in King County facilities, extrapolation statewide is 

necessary. Due to the limitations discussed on page 3, extrapolations, like the survey 

results, should be viewed only as descriptive data about drug waste management. Table 

15, Extrapolation of Waste Generated Statewide, on the following page, offers one of 

several possible methods to do this. The extrapolation in Table 15 is based on the 

information in Table 16, Patient Contact per Day per Business Type, and Table 17, and 

Average Quantity of Waste per Business. Additionally, the qualitative information 

regarding barriers to proper disposal of pharmaceuticals that was provided by the industry 

in this survey is useful statewide. 
 

20 King County - Pharmaceutical Waste Survey 

Table 15. Extrapolation of Waste Generated Statewide 

Facility Description Average Pounds 

Pharmaceutical 

Waste/Facility/Year 

Estimated # Facilities 

in Washington State16

Extrapolated Quantity 

of HW Generated 

per Year 

Ambulatory/ surgical 

centers 

5 50 250 lbs 

Dialysis centers 12 12 144 lbs 

Doctors offices 

(includes podiatrist) 

3 5,800 17,400 lbs 

Hospitals (IV Fluids) 6,900 110 759,000 lbs 

Hospitals (Other 

wastes) 

490 110 53,900 lbs 

Nursing/boarding 

homes 

8 900 7,200 lbs 

Pharmacy – retail17 5 1068 5,340 lbs 

Specialty Outpatient 42 3,900 163,800 lbs 

Veterinary – small 

animal 

1 1361 1,361 lbs 

Pharmaceutical waste generated in Washington state each year by 

health care industry. 759,000 lbs (75 percent) of this amount consists 

of IV fluids that are not expected to designate as dangerous in WA. 

1,008,395 lbs 

Pharmaceutical waste generated in Washington state each year by the 

health care industry, not including IV fluids. 

249,395 lbs 

 

16 Numbers for practitioner offices/clinics and hospitals are per Morrison. Numbers for pharmacies from 

Stan Jeppesen, WA Board of Pharmacy. Number of dialysis centers is from infoUSA. 

17 One pharmacy surveyed collected drug wastes from 54 locations statewide, but was counted as one 

pharmacy in N=5. 
 

King County - Pharmaceutical Waste Survey 21 

Table 16. Patient Contact per Day per Business Type 

Facility Description Average # Patient 

Contact / Day / Facility 

Estimated # Facilities 

in Washington State18

Estimated Contact / 

Day / Facilities in WA 

Ambulatory/ surgical 

center 

N = 6 

72 patients/day 50 3,600 patients 

Doctors Office 

(includes podiatrist, 

dialysis, specialty 

outpatient clinics) 

43 patients/day 10,000 43,000 patients 

Hospital 

N = 5 

382 beds/facility 110 42,020 beds 

Nursing/boarding 

home 

N = 4 

111 beds/facility 900 99,000 beds 

Pharmacy – retail19

N = 5 

220 Rx filled/day 1068 234,960 Rx 

Veterinary – small 

animal 

34 patients/day 1361 46,274 patients 

 

18 Numbers for practitioner offices/clinics and hospitals are per Morrison. Numbers for pharmacies from 

Stan Jeppesen, WA Board of Pharmacy. 

19 One pharmacy surveyed collected drug wastes from 54 locations statewide, but was counted as one 

pharmacy in N=5. 
 

22 King County - Pharmaceutical Waste Survey 

The quantity and facility data was reviewed to see if estimates of the pounds of waste per 

facility could be developed. The data has gaps; for example one facility may not have 

quantity data for all waste streams. However, table 15 below summarizes those averages 

that could be computed. To convert the quantities reported into pounds, milliliters were 

converted assuming the density of water (1 g/ml), pills were determined to average 0.55 g 

each20, debris was assumed to be 1 gallon each, and syringes were assumed to average 2 

g each. For pills, the conversion to pounds is for the pill only, and does not include the 

amount of packaging discarded with the pill. Again, the table demonstrates the influence 

of high-density IV fluids (27,650 pounds of the total generated by hospitals) on the 

quantities generated per facility. Those IV fluids containing drugs, and those without 

drugs, could not be separated out from the data provided. 

Table 17. Average Quantity of Waste per Business 

Total Amount 

Generated 

Average Amount 

Generated per Facility 

per Year 

Business Type Number of 

Facilities with 

Quantity Data 

Number of 

Wastestreams 

with Quantity 

Data 

In Units of Pounds 

ambulatory/ 

surgical center 

5 7 26 5 

dialysis center 1 1 12 12 

doctors office 14 24 43 3 

hospital – IV 

fluids 

4 8 27,650 6,900 

hospital –other 4 2 1,950 490 

nursing/ 

boarding home 

1 1 8 8 

pharmacy – 

retail21

56 56 292 5 

podiatrist 2 3 6 3 

specialty 

outpatient 

8 12 335 42 

veterinary 7 13 9 1 

Total 102 127 30,331 

 

20 On 11/12/02 Bill Rowe, with the University of Washington, weighed a random assortment of 50 pills of 

varying sizes, shapes and drug active ingredient. The total weight was 27.6 g for an average of 0.55 g/pill. 

21 These wastes were sent to reverse distributors. 
 

King County - Pharmaceutical Waste Survey 23 

APPENDIX A 

SURVEY FORM 
 

24 King County - Pharmaceutical Waste Survey 
 

King County - Pharmaceutical Waste Survey 25 
 

26 King County - Pharmaceutical Waste Survey 
 

King County - Pharmaceutical Waste Survey 27 
 

28 King County - Pharmaceutical Waste Survey 
 

King County - Pharmaceutical Waste Survey 29 

APPENDIX B 

SURVEY PROTOCOL 
 

30 King County - Pharmaceutical Waste Survey 
 

King County - Pharmaceutical Waste Survey 31 

Project 

IRAC’s Pharmaceutical Workgroup is conducting a survey and needs data from 84 health 

care facilities within the next two weeks. The following wonderful people have agreed to 

conduct up to twelve surveys, either by visiting in person or by telephoning the facilities: 

Ann Peacock, Sue Hamilton, Emmanuel Rivera, Lisa Niehaus 

Alice Chapman, Cheri Grasso and Debra Oliver are also doing the survey and are part of 

the IRAC workgroup. They can answer (or try to) the questions you may have and 

provide guidance, although they’ve visited as many of these facilities as you have! 

Background 

The Washington State Board of Pharmacy, in collaboration with the Interagency 

Regulatory Analysis Committee, is interested in learning about the quantities, types, 

disposal and fate of pharmaceutical wastes. We are in the process of collecting data to 

evaluate the best disposal options available to keep toxic drug wastes out of the 

environment, inaccessible to diversion and to comply with laws governing their disposal. 

The range of wastes we are interested in is all-inclusive: 

Prescription drugs (like nitroglycerine), over-the-counter drugs (cold meds, 

vitamins, diuretics, etc.), controlled substances (e.g., morphine), chemotherapy 

drugs and materials (like IV tubing, gloves and gowns), doctor’s-order drugs 

(from the leftovers in a syringe to spilled aspirin), and contrast media and dyes 

used for diagnosis. 

We need your help to learn more about pharmaceutical wastes and appreciate your time 

answering questions for us. 

For your information only 

The IRAC Workgroup is testifying at Ecology’s public hearing on October 29 and needs 

preliminary data to support the proposed language that will conditionally exclude 

controlled substances and legend drugs from the Dangerous Waste Regulations. The 

condition is that these substances are destroyed in a specific type of combustion unit – 

not a medical incinerator, but a state-of-the art waste-to-energy unit that burns for a 

longer time and at a temperature that does not create furans or dioxins. As the regulations 

stand now, the health care industry must designate and properly manage their waste 

pharmaceuticals. 
 

32 King County - Pharmaceutical Waste Survey 

Suggestion for an Opening 

I am _________________ with King County. We are working with the Board of 

Pharmacy on a study of how waste or unusable pharmaceuticals are disposed of – 

how, where and how much – and we need your help. [Or Who would be the best 

person to talk to about this for 15 –20 minutes...] Would you be willing to allow 

me to spend about 15-20 minutes with you at your facility to help me with the 

questionnaire? Or, if you and they are able to do this over the phone, go ahead. 

Differences between medical industry and other industries we 

have visited: 

Categories are different. Medications are categorized according to their use (antibiotic, 

nutrient, psychotropic, narcotic, etc.) or their state (tab, solution, topical); but have not 

been categorized according to hazard, ingredients, or chemical classification. The active 

ingredients in pharmaceuticals do not have the type of toxicity data that the DW 

regulations require in order to designate them. Some RCRA-regulated drugs have been 

designated, but it is unlikely that it is widely known or understood among the facilities 

we will survey. 

Vocabulary/Jargon 

Reverse Distributors are businesses that “buy back” unused/expired pharmaceuticals 

from medical facilities. The facility sends their expired or unusable pharmaceutical 

products to a reverse distributor (RD). The RD sorts and destroys (via a RCRA/HW 

incinerator) expired or unsold drugs that it cannot return to the manufacturer for credit. 

The RD sends products that fit manufacturer’s criteria for credit to the manufacturer and 

keeps a percentage of the credit the facility would have received. The medical 

community assumes the drugs they receive credit for are being reused by the 

manufacturer or “recycled.” 

This service came about when manufacturers, in order to encourage pharmacies and 

medical clinics to try their new drugs, offered a money-back guarantee for unused drugs 

they agreed to try. RDs capitalized on the credit. This service is usually only available to 

hospitals or other large medical facilities. Common reverse distributors are MedTurn, 

Easy Returns, and Capital Returns. The EPA has written that those unusable 

pharmaceuticals in the reverse distribution system are considered product until declared 

waste by the RD or manufacturer. 

Hazardous in their eyes means biohazardous. Red bags are not always red. 

Destroyed often means a drug has been put into the garbage disposal or down the sink 

drain. 

Tabs/Caps – Tablets and capsules, pills, oral solids, PO. We expect to find more of this 

type of medication than any other. Includes aspirin, blood pressure medicine, etc. 
 

King County - Pharmaceutical Waste Survey 33 

Bingo Cards – These are also called “blister packs.” They are packages of single doses 

of medications, usually four or five units across by four or five units down. A molded 

plastic cover seals the individual tablets or capsules to a foil-covered card, through which 

one pushes the tablet or capsule. 

Solutions – This includes antibiotics, cough syrups, etc. 

Injectables – Insulin, vaccines, flu shots, etc. Leftovers are sometimes “wasted” down a 

drain. 

Chemo – This is short for “chemotherapy” or chemical therapy and involves the use of a 

lot of drugs – often via IV. We have often confused it with Radiation Therapy, but it has 

nothing to do with that, except that both therapies are used in fighting cancer. 

Contrast Media – These include dyes that are used in radiology to provide contrast in xrays and other tools for diagnosis. This includes some radioactive materials, but they’re 

regulated separately. We don’t know a lot about this category. 

Debris – This is our word, on the form where we are asking for the nature of the waste. 

By debris we mean the paraphernalia associated with the medications that may have been 

contaminated and now needs to be disposed of – paper cups, syringes, etc. In 

chemotherapy, the patient consumes most of the medication. What is waste is usually 

handled properly; however, in addition to the wasted medicine are the gloves, gowns, IV 

tubing, etc., that may have been exposed to the medication. 

TPN and IVP – total parenteral nutrients and intravenous parenterals. These are IV bags 

with fluids (water, dextrose, saline, electrolytes, etc.) given to someone who can’t eat 

(right after surgery). Don’t include these unless they contain medication. We don’t expect 

to see them outside of hospitals and nursing homes. 

Legend drugs – These are drugs that require a prescription. The “legend” is the 

statement that appears on every container of prescription drugs that says it is unlawful to 

transfer to anyone other than the patient for whom it was prescribed. 

Controlled substances a/k/a “narcs,” controls, or scheduled drugs – These are tightly 

regulated by the Drug Enforcement Administration due to their likelihood for diversion 

and abuse. These must be destroyed in front of a witness. The most common form of 

destruction we expect to find is down the drain. We also expect that facilities will have 

paperwork for all their controlled substances but not for legend drugs. 

PO – Short for the Latin phrase per oss, which means “by mouth” and will in some cases 

refer to pills taken orally. These are also called oral solids. 

Survey form info 

Starting with the optional questions may help you build rapport and ease any discomfort 

with the survey. On the first not-optional page of the questionnaire the first question, “Do 

you keep records....” is your key to an easier time of it! Ask to see their records! 
 

34 King County - Pharmaceutical Waste Survey 

We will have to get their best estimates on volumes, numbers, frequencies, etc. In one 

clinic, Alice sat the waste drug box on her survey sheet and traced its height, width and 

depth to figure out its volume back in the office. Do whatever it takes! 

Also, take advantage of the process flow page if you get some good information on the 

life cycle of some type of drug. This is something Ecology wants. 

The numbers of patients served per unit of time (week, month, whatever) is extremely 

important because we will extrapolate our data across the state using that constant. The 

number of RNs may be used in the same way, please don’t forget that one! 

Special Information in Doctors’ Offices Regarding Samples: 

For samples in doctors’ offices, we need to know the number of doctors with access to 

the sample stash (for extrapolation), the amount that gets wasted, and whether or not the 

supplier takes it back. We think in doctors’ offices that this is a large volume 

wastestream. 
 

King County - Pharmaceutical Waste Survey 35 

APPENDIX C 

SURVEY PLAN AND CONSIDERATIONS 
 

36 King County - Pharmaceutical Waste Survey 
 

King County - Pharmaceutical Waste Survey 37 

Area to Survey # to Survey Major source of 

waste expected 

Data needed for 

extrapolation 

Survey considerations 

OutpatientClinics 

Ambulatory or 

Surgical Care Ctr 

NAICS 6214--* 

Offices of MDs 

and ODs 

NAICS 6211-- 

Etc Practitioners 

NAICS 6213-- 

10,000 in WA1

Wt = 2.52

10,000/100*2.5=250

Samples Volume of samples, 

Est. closet or bin size 

# physicians w/ access 

to each sample stash 

Diversity – 

Get large, small, groups, 

individuals, affiliated w/ hosp 

and not (difference?) 

Capture also podiatrist, 

inhalation /respiratory 

therapist 

Dialysis center (Stan) Need 

list of centers in state and # 

patients served in state 

Diagnostic 

Imaging Centers 

NAICS 62151- 

Include with clinics Contrast media # patients served / 

population / not sure 

how to extrapolate... 

Nursing Homes 

NAICS 623110 

400 in WA1 

Wt = 12

400/100*1=4

Oral solids # patients served or 

number of beds 

Interview nurses 

Measure waste 

accumulated in bin over 

what time? 

Lic’d by DSHS, include 

skilled nursing staff

Can we get # of beds / home / 

county / state? 

Boarding Homes, 

e.g., Adult Family 

Homes 

NAICS 6232-- 

500 in WA1

Wt = 12

500/100*1=5

Oral solids 

Bingo cards 

# of residents served. 

Interview person in 

charge for meds 

wasted. HHW? 

Domestic sewage 

excl? 

No skilled nursing staff.

Need list of homes and # 

beds by home in WA. 

Check with DSHS website. 

Pharmacies 

NAICS 446110 

1200 in WA1

Wt = 12

1200/100*1=12

Oral solids 

Bingo cards – those 

returned to pharmacy 

by others (are full cards 

reused and partials 

returned to RD?) 

Types of pharmacies: 

- Retail 

- Serves nursing home 

- Institutional or hospital 

pharmacy 

Stan will call several 

pharmacies to find out if any 

toss out their waste 

pharmaceuticals. 

Hospitals 

NAICS 6221-- 

110 in WA1

Wt = 32

110/100*3=3

Oral solids 

Injectables 

Solutions 

Topicals 

Swedish 

Virginia Mason 

- done 

- go back for photos 

- Pyxis info to come 

Harborview/UW 

- do 

Need # pts served in 

hospital, # beds, # beds 

in WA state 

Need to extrapolate data 

across WA using # patients 

Need to know # patients 

served on annual basis by 

hospital diagnostic imaging 

centers – will apply D.I.C. into 

to hospitals. Same re O.R . 

(capture under surgical 

center) 

Reverse 

Distributors 

NAICS 562920 

Wt = 0 

Get one anyway 

 PSI, Easy Returns 

Capital Returns 

Med-Turn (Auburn) 

Veterinary clinics 

NAICS 541940 

Wt = 0 

Get one or two anyway 

# non-food animals 

served per hospital, # 

hospitals in WA 

Small & large animal – nonfood! 

1 – These state-wide estimates are taken from Don Williams’ (WA DOH Board of Pharmacy) presentation by to the 

IRAC Pharmaceuticals Workgroup, April 2001. For the purposes of this survey, we may choose to use King County 

numbers.

2 – Weights were determined by Tom Georgianna, KC DNR Statistician, in meeting with Stan Jeppesen, Cheri Grasso, 

Alice Chapman, Brian Westra and Debra Oliver on 10/8/2002.

* – NAICS Codes are provided in as much detail as possible given the broad or specific range of industries within the 

class. 
 

38 King County - Pharmaceutical Waste Survey 

From Tom Georgianna: What question drives everything? What will we do with the data? 

Answers: Show Ecology the totals. How much goes to SS, SW, RD, BioH, etc. 

From Stan Jeppesen: Breakdown by drug class is impossible; has never been done. Some RCRA 

drugs have been designated/classified. 

We will look for: 

Oral Solids or Tabs/Caps. This is what we see most of – aspirin, high blood pressure meds, etc. 

Solutions. This includes cough syrups, some antibiotics, etc. 

Injectables. Insulin, vaccines, flu shots, etc. 

TPNs and IVPs. Nutritional fluids, include dextrose, saline, electrolytes. Expect huge volumes in 

home health care situations (HHW), but small volumes in hospitals and nursing 

homes. Expect it to be of no consequential value. Will not include in this survey. 

 However, we do need to do some research on these fluids. 

Chemo. This is unnecessary as chemo waste is properly managed as hazardous waste; however it is a good 

place to start the survey. 

For data entry, we must simplify and collect the following fields: 

Tabs/Caps  Nominal Wt Quantity Unit of Msrmt 

Solutions  of Tab/Cap 

Injectables  

Topicals  _________ _________ _________ 

And we need a conversion factor so all of these can equal one or two units of measurement, e.g. mg or cc 

Hospitals: PO = # tabs or caps/week wasted Injectables = mg/wk wasted = Ratio 

 #units issued #units issued 

We can find this ratio using information from Virginia Mason & Swedish Pyxis system used to track 

controlled substances and apply the ratio to legend drugs, then / patients served to extrapolate statewide. 

We may have to use billing information from hospitals to get some handle on the amounts of legend drugs 

consumed. 

Nursing Home: 

Interview nurses for wasted injectables. 

Examine the waste bin for quantity of drugs over quantity of time / number of patients. 

# tabs, caps, cc’s of inj wasted / patients served or beds => extrapolation 

Example: 1⁄2 of one oral solid wasted per patient per week = total tabs wasted multiplied by 

number of patients in WA nursing homes 

Waste bins: 

UW – Bill R. and Doug G: Can they examine the contents of waste drug bins and determine 

the weights of both packaging and product in a box to project X box volume = Y drug waste? 
 

King County - Pharmaceutical Waste Survey 39 

APPENDIX D 

PROCESS FLOW DIAGRAMS BY BUSINESS TYPE 
 

40 King County - Pharmaceutical Waste Survey 
 

King County - Pharmaceutical Waste Survey 41 

Doctor’s Office, Urology (Visit 17)

Drug samples - Check dates

Donated to 

charity

Down the 

drain

Expired

Date OK

IV fluids with 

drugs to patient

Empty 

tubing 

& bags

Biohazardous 

waste

Injectables & 

multidose vials 

-antibiotics 

-hormones 

-anesthetics

Injection 

used (all)

Biohazardou

s 

Injectable Injection 

partially used

Biohazardou

s 
 

42 King County - Pharmaceutical Waste Survey 

Ambulatory/Surgery Center (Visit 27)

Pills from 

Pharmacy

Check dates of 

unused pills

Returned to 

pharmacy

Expired Down drain

Date OK

Demerol injection 

from Pharmacy

Injection 

partially used

Sharps 

container to 

Squirted into 

sink drain

Demerol

Empty 

syringe

Ampoules from 

Pharmacy

Ampoule 

partially used

Biohazard 

container to 

Stericycle
 

King County - Pharmaceutical Waste Survey 43 

Narcotic injection 

from pharmacy

Injection 

partially used

Squirted into 

linens

Squirted into 

sink drain

Sometime

Sometime

Ambulatory/surgical center (Visit 28)
 

44 King County - Pharmaceutical Waste Survey 

Specialty outpatient (Visit 37)

Pharmacy 

purchases drug

Date expired DEA-licensed 

vendor
 

King County - Pharmaceutical Waste Survey 45 

Specialty outpatient (Visit 44)

Vendor provides 

drugs (birth 

control, allergy)

Date expired In a box, never 

disposed
 

46 King County - Pharmaceutical Waste Survey 

Doctors office (Visit 51)

Sample drugs Date expired Sewer

DEA drugs Date expired Witnessed 

disposal to 

Injectables (single 

dose vials)

Injected (all) Empty vial & 

syringe to 

biohazard 

container
 

King County - Pharmaceutical Waste Survey 47 

Doctors office (Visit 54)

Sample pills Date expired Biohazardous 

waste
 

48 King County - Pharmaceutical Waste Survey 

Podiatrist (Visit 55)

Sample drugs Date expired Biohazardous 

waste
 

King County - Pharmaceutical Waste Survey 49 

Drug samples 

from 

Drugs expired

Biohazardous 

waste

Sometime Garbage

Sometime

Specialty outpatient (Visit 56)

Sometime Returned to 

IV fluids with 

drugs to patient; 

injectables

Vials, tubing 

 & debris 

emptied 

(drug to

Biohazardous 

waste
 

50 King County - Pharmaceutical Waste Survey 

Specialty outpatient (Visit 57)

Drug samples 

received from 

main clinic

 Drug Disposed to 

biohazard 

container & sent 

to main clinic
 

King County - Pharmaceutical Waste Survey 51 

APPENDIX E 

WASTE QUANTITY DATA BY BUSINESS TYPE 
 

52 King County - Pharmaceutical Waste Survey 
Waste Quantity Data by Business Type

Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

ambulatory/surgical center

Injectable anesthetics

waste about 1 mg drug (active ingredient) per week for a total of approximately 8 patients per week, no data on total amount of waste

ampoules partially used no data

Count of wastestreams generating this quantity: 2 Subtotal

Empty syringe no meds in syringes, generated 

during flu season

2,500 per year 2500 

Count of wastestreams generating this quantity: 1 Subtotal 

2500

injectables fentanyl, demerol, versed, 

morphine - controlled substances; propofol, lidocaine, marcaine

42 cases over 7 days, average 205 cases/month, with (a very close estimate) 3117 mg active ingredients - calculates to 50 cc solution per week

2600 

liquids narcotics 10 cc per year 10 Partial injections Demerol maybe once per month 12 injectable anesthetics

narcotics, Propofol, Versed Average approximately 3 cc per 

patient, range 2-5 cc's". 3 ml/pt x 250 pt/mo x 12 mo/yr = 9000 ml/yr

9000 

Leftover narcotic 10 cc per month 120 

Count of wastestreams generating this quantity: 5 Subtotal 

11742

pills 10 doses per year 10 

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

Pills Unused expired pills less than 25 per year 24

Count of wastestreams generating this quantity: 2 Subtotal 

34

dialysis center

Betadyne disinfectants

spray bottles used, disinfectant wiped up with rags

"no waste" however, waste rags are going into the garbage

Count of wastestreams generating this quantity: 1 Subtotal

Injectables only heparin and IV iron may 

typically become waste

estimated at much less than 15 cc/day of total injectables; assumed 15 for estimate below: 15 ml/day x 365 day/yr = 5475 ml/yr

5475 

Count of wastestreams generating this quantity: 1 Subtotal 

5475

doctors office

samples two physicians give out about 90% 

of samples, leaving 10% waste

quantity of sample waste is unknown

DEA drugs no quantity/volume data availableother, mostly gloves

most of our waste

Count of wastestreams generating this quantity: 3 Subtotal

syrup one pint/month 6405 injectables DHE - single-dose vials no drug waste - drug all used up. 

Just the syringe

0 

antibiotics about once a month they have 1/2 

ml of waste

6 

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

vaccine about once a mnoth they have 1/2 

ml of waste

6 

Oral solids and unused injectables

Bottles of pills are emptied into the biohazard container located in the pharmacy. Empty pill bottles go in regular garbage. Unused injectable liquids in vials also go into the pharmacy biohazard container.

One gallon container filled every 6 months.

7571 

Used injectables About once a month, an individual 

dose is withdrawn from a septum vial of injectable drug that is less than the total amount in the vial. The left-over liquid (about 1 cc) in the vial is disposed into the biohazard container with the used injection sharp. Sometimes the pharmacist adds used sharps/vial waste from teaching patients selfinjection.

One cc in one vial per month 12 

expired samples usually liquids she really couldn't give me a 

number. But she agreed that it was probably once a month they would have some liquids they would flush down the toilet. I will assume the smallest number 1 ml even though this is a huge facility

12 

liquids 2 cc per year 2 unused injections once every 2 to 3 months they 

have about 1 cc of waste injection to put into sharps container

5 

one dose one dose, between five and ten 

ccs every six months

15 

expired meds once every 6 months 24 oz goes 

down the drain

1421 

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

Liquids Typical wastes are cough syrup 

and lidocaine.

cough syrup 240 ml/yr other (e.g., lidocaine) 100 ml/yr.

340 

vaccines about once a month they have 1/2 

ml of vaccine they have to waste

6 

Count of wastestreams generating this quantity: 13 Subtotal 

15801

expired samples and pills

2000 in last four months 6000

pills about once every 6 months we 

have 6 bills we throw in the garbage

12

outdated samples 20 pills every 6 months 40

pills/powder 10 doses / month 120pills one or two doses one or two doses (pills) per month 18

5 pills per year

5

samples and pills 25 boxes of four pills each 100pills (samples) pills-samples 6 to 10 a year in the 

biohazard

8

samples I check the samples about every 3 

or 4 months. I find about 10 samples that have expired. They have 1 or 2 pills in each sample

60

expired samples about every month there are 2 

boxes of pills in bingo cards, around 6 pills in each bingo card

144

oral solids neurology clinic - pills only on site 

in bingo cards

20 to 50 pills in bingo cards every three months

140

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

expired meds about every 6 months they have 3 

or 4 boxes of pills (5 pills in ech box average) that expire. We throw them in the garbage

35

expired pills one of the doctors take the expired 

pills to Latvia. Also they have in the past sent some to World Concern. I got her to give me a range and she agreed to "more than a dozen in a year" I will assume that each packet contains 4 pills 4 x 13 = 52

52

expired samples about once every 6 months they 

hve 12 or less pills. They crush the pills, soak them in water and put down the drain

24

Count of wastestreams generating this quantity: 14 Subtotal 

6758

hospital

Narcotics DEA controlled substances contact to compile data from Pyxis 

computer system

legend injectables generated at pharmacy IV room, 

legend drug (<1%) combined with a solution composed primarily of potassium, phosphorus, calcium, magnesium, insulin, normal saline

contact unable to estimate

Narcotics - other miscellaneous

DEA controlled substances contact checked Pyxis system for 

quantity data; 1015 mgs disposed

Narcotics - solution based

DEA controlled substances contact checked Pyxis system for 

quantity data; 15 mls disposed

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

Chemo, <3% If chemo remaining in container is 

< 3% of the total waste, it goes to solid waste. Site referred to this as the bag factor.

contact to compile data from Pyxis computer system; most chemo waste is managed this way

TPN total parenteral nutrition, patient 

receives nutrients through IV, may not designate as hazardous, contains amino acids, dextrose, enzymes, vitamins (K &C), potassium, calcium, sodium and saline solution

contact compiled data from Pyxis computer system, 28.4 liters over 13 days

Narcotics - injectables

DEA controlled substances contact checked Pyxis system for 

quantity data; 448 mg disposed

Presser, ICU IV liquids that regulate blood 

pressure, commonly prescribed for patients coming out of surgery and in the intensive care unit

contact to compile data from Pyxis computer system; amount is expected to be small

OTC over-the-counter drugs expired drugs go to reverse 

distributor, don't generate waste OTCs

OR drugs Anesthetics, controlled 

substances, and other drugs used in surgery

contact to compile data from OR records

Oral solids Antibiotics and other pills or tablets initially said that 1% of the time, 

waste may be generated; however, contact checked Pyxis records and all oral solids were returned to reverse distributor, but no quantity data was available

Narcotics - tabs/caps

DEA controlled substances in solid tablets or caplets.

contact compiled data from Pyxis computer system; 8765 mg active ingredient, timeframe?

Count of wastestreams generating this quantity: 12 Subtotal

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

Chemo Chemotherapy drugs in solution in 

a vial or in a bag

10 gallons per week 1968408 

Expired solutions saline solutions, total parenteral 

nutrition, most don't contain medicine

10-20 liters per day 3650000 

Presser, nurse's station

IV liquids that regulate blood pressure

10 bags (250 cc each) per day 912500 

Hydrations normal saline, dextrose-based 

solutions, not likely to designate as dangerous waste

contact obtained data from Pyxis system, 189.3 liters over 13 days

5315000 

IV room Expired small volume parenteral 

liquids, septum lid vial size ranged from 2 ml to 100 ml, partially filled with leftover or expired solutions, some bags

60 liters per month (dumped daily) 720000 

Count of wastestreams generating this quantity: 5 Subtotal 

12565908

Narcotics C-II 45.28 grams over 5 months

0

Chemo, >3% If chemo remaining in container is 

>3% of the waste, it is collected as hazardous waste.

25 pounds per 9 months (assumed this is total waste)

33

If chemo remaining in container is >3% of the waste, it is collected as hazardous waste.

385 pounds per 9 months (assumed this is total waste)

513

Oral drugs Most are packaged for individual 

doses, most in "bingo cards" and some in resealable bags labeled for a particular patient, several are antiviral drugs

cardboard box lined with red bag, about 1/2 drum size (25 gal) is filled every 2 weeks; estimated weight includes packaging

80

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

Chemo, >3% If chemo remaining in container is 

>3% of the waste, it is collected as hazardous waste.

data compiled from Pyxis computer system; 995 pounds for 9 months (unclear whether this is total waste or active ingredient, assumed it was total waste).

1327

Count of wastestreams generating this quantity: 5 Subtotal 

1953

nursing/boarding home

tabs & pills 125 pills/week 6500

Count of wastestreams generating this quantity: 1 Subtotal 

6500

other accounting

no data

Count of wastestreams generating this quantity: 1 Subtotal

pharmacy - retail

all wastes oral solids, injectables, topicals 

and oral solutions, even dropped tabs

no waste, all, even dropped tabs, returned

pills, tabs, etc. no quantity information given

Count of wastestreams generating this quantity: 2 Subtotal

oral solids estimated at 100 mg each 25 tabs or caps / year, each tab = 

100 mg, 2500 mg/year

300

Count of wastestreams generating this quantity: 1 Subtotal 

300

pills and tablets expired OTC and Rx products Products not returned to reverse 

distributor estimated to be 3 pounds per month - gross weight

36

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

pills & tabs miscellaneous dropped and 

unidentified pills and tablets

From all 54 stores, eight liters of misc pill are collected, each liter weighing about two pounds

16

pills and tablets All expired, unused, partial and full 

pharmaceuticals

Eight boxes (18" square) weighing an estimated 20 pounds each are collected from the 54 Bartells stores

240

Count of wastestreams generating this quantity: 3 Subtotal 

292

podiatrist

gloves, gowns and plastic

this is the majority of our waste - no quantity information given

Count of wastestreams generating this quantity: 1 Subtotal

ointment/lotion most are outdated samples about one cup per month 2842 

Count of wastestreams generating this quantity: 1 Subtotal 

2842

expired samples there is about 1 pill per packet and 

we have maybe 5 pills per year

5

pills mostly outdated samples about 20 per month 240

Count of wastestreams generating this quantity: 2 Subtotal 

245

reverse distributor

IV solns/oral solns/lg vials, etc.

controlled substances regulated by DEA

881 pounds over a nine month period (packaging removed, and includes basic container packaging

1175

legend drugs 27 pounds (packaging removed, 

and includes basic container packaging) over a nine-month period

36

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

tabs/caps/vial/inj/patches/otic, etc.

controlled substances regulated by DEA

241 pounds in nine months (after packaging removed, and includes basic container packaging)

321

tabs/caps/vials/inj/patches/otics, etc.

legend drugs 151 pounds (after packaging 

removed, and includes basic container packaging) over a ninemonth period

201

Count of wastestreams generating this quantity: 4 Subtotal 

1733

specialty outpatient

samples from reps (pills)

receptionist was unable to estimate the amount

injectable antibiotics, hormones, anethetics no meds disposed, only sharpspills samples shared by three doctors; 

less than 5% of samples are wasted

very small quantity <5%

samples/pills Guide unable to estimate aste 

volume of samples and pills generated by three physicians and one physician assistant

Class 2 Narcotics expired no idea; person questioned said he 

purchases for 80 different doctors and clinincs, but has nothing to do with disposal

Count of wastestreams generating this quantity: 5 Subtotal

debris IV tubing, syringes one IV tubing/syringe/gloves, etc. 

per month

36 

IV tubing, syringes one IV tubing/syringe/gloves, etc., 

per month

36 

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

vaccine sharps Occasionally a vaccine might 

expire, but it's very rare. We don't keep anything in stock - very few injections. We order only the amount we need and send expirations to the pharmacy. We dispense meds through AllScript. We have multidose vials of Lidocaine, but use them up and have no waste. We also have some Neosporin, an antiflammatory.

18 

IV debris IV meds and debris. All the meds 

are used up

2 doses per month 24 

Count of wastestreams generating this quantity: 4 Subtotal 

114

injectables diuretics, fluids Guide said rarely administer IVs or 

injections. Estimate IV fluids at 1000 cc/month; injectables at 5 cc/month

12060 

liquid inhaler 50 cc ev 6 months 100 injectable lidocaine 2 cc lidocaine left in syringe / 10 

vasectomies a month

240 

5 cc ev 6 months 10 0.5 cc 2c/wk 52 

narcotic 1 cc ev 3 months 4 injectable 1 cc ev 3 months 4 

one cc / two weeks 26 

expired IV meds one sandwich-sized Ziploc bag 50 

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

Count of wastestreams generating this quantity: 9 Subtotal 

12546

pills 10 pills ev 6 months 20

oral solids expired birth control and allergy 

pills

20 or 30 per month 30

antibiotics 5 to 10 pills/quarter 30

Count of wastestreams generating this quantity: 3 Subtotal 

80

veterinary

Chemo Chemotherapy drugs for animals, 

not a common vet procedure because pet owners often can't afford treatment.

Very small quantity

Chemotherapy drugs for animals, not a common vet procedure because pet owners often can't afford treatment.

Very small quantity

Chemotherapy drugs for animals, not a common vet procedure because pet owners often can't afford treatment.

Very small quantity

Tablets/pills Tablets/pills none disposedChemo Chemotherapy drugs for animals, 

not a common vet procedure because pet owners often can't afford treatment.

Very small quantity

Count of wastestreams generating this quantity: 5 Subtotal

Hg thermometers 2 thermometers per year 2 

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

Count of wastestreams generating this quantity: 1 Subtotal 

2

injectable anesthetics

Ketamine/valium 99+% and Propathal

0.5 ml/day 183 

injectable anesthetic 1.5 cc twice a week 150 

expired injectables 100 cc year 100 

injectable anesthetics

Ketamine/valium 99+% 3-5 ml/day 1460 

Ketamine/valium 99+% 1 ml/day 365 Ketamine/valium 99+% 1 ml/day 365 Ketamine/valium 99+% 2 ml/day 730 Ketamine/valium 99+% 1 ml/day 365 

injectable antibiotic 10 cc week 500 

Count of wastestreams generating this quantity: 9 Subtotal 

4218

Tablets/pills Tablets/pills 6 tablets or pills per year

6

Tablets/pills none disposed

0

Tablets/pills none disposed

0

Tablets/pills none disposed

0

Count of wastestreams generating this quantity: 4 Subtotal 

6

Chlorhexidene Disinfectant/irrigant for wounds, 

absorbed with surgical scrubs or sterile gauze

3 cups per year plus debris (assumed 3 cups weighed 2 pounds and debris weighed 2 pounds)

4

Tuesday, November 12, 2002 
Business Type Waste Name Waste Name Description Generation Rate Description Quantity 

per Year

Count of wastestreams generating this quantity: 1 Subtotal 

4

Tuesday, November 12, 2002 
 

King County - Pharmaceutical Waste Survey 67 

APPENDIX F 

WHERE ARE DRUG WASTES DISPOSED? 
 

68 King County - Pharmaceutical Waste Survey 
Where are Drug Wastes Disposed?

Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Comments

No data

Narcotics - tabs/caps DEA controlled substances in solid 

tablets or caplets.

contact compiled data from Pyxis computer system; 8765 mg active ingredient, timeframe?

Notes unclear, sanitary sewer? Solids also?

legend injectables generated at pharmacy IV room, 

legend drug (<1%) combined with a solution composed primarily of potassium, phosphorus, calcium, magnesium, insulin, normal saline

contact unable to estimate

Narcotics - other miscellaneous

DEA controlled substances contact checked Pyxis system for 

quantity data; 1015 mgs disposed

Narcotics - solution based DEA controlled substances contact checked Pyxis system for 

quantity data; 15 mls disposed

Narcotics - injectables DEA controlled substances contact checked Pyxis system for 

quantity data; 448 mg disposed

no data

Count of wastestreams generating this quantity: 6 Subtotal

Down the drainTuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition CommentsPresser, ICU IV liquids that regulate blood 

pressure, commonly prescribed for patients coming out of surgery and in the intensive care unit

contact to compile data from Pyxis computer system; amount is expected to be small

All solutions except chemo go to the sanitary sewer. Emptied debris goes to solid waste

DEA drugs no quantity/volume data availablewitnessed disposal to sewerInjectable anesthetics waste about 1 mg drug (active 

ingredient) per week for a total of approximately 8 patients per week, no data on total amount of waste

TPN total parenteral nutrition, patient 

receives nutrients through IV, may not designate as hazardous, contains amino acids, dextrose, enzymes, vitamins (K &C), potassium, calcium, sodium and saline solution

contact compiled data from Pyxis computer system, 28.4 liters over 13 days

All solutions except chemo go to the sanitary sewer. Emptied debris goes to solid waste

Count of wastestreams generating this quantity: 4 Subtotal

injectable anesthetics Ketamine/valium 99+% 2 ml/day Goes into the sinkinjectable anesthetics Ketamine/valium 99+% 1 ml/day Goes into the sink

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Commentsinjectables fentanyl, demerol, versed, 

morphine - controlled substances; propofol, lidocaine, marcaine

42 cases over 7 days, average 205 cases/month, with (a very close estimate) 3117 mg active ingredients - calculates to 50 cc solution per week

These are mostly controlled substances that are "wasted" down the drain as that is the only safe way known to us to deal with narcotics

IV room Expired small volume parenteral 

liquids, septum lid vial size ranged from 2 ml to 100 ml, partially filled with leftover or expired solutions, some bags

60 liters per month (dumped daily) 7

Expired solutions saline solutions, total parenteral 

nutrition, most don't contain medicine

10-20 liters per day 36

injectable anesthetics Ketamine/valium 99+% 1 ml/day Goes into the sinkinjectable anesthetics Ketamine/valium 99+% 1 ml/day Goes into the sinkinjectable anesthetics Ketamine/valium 99+% 3-5 ml/day Goes into the sinkHydrations normal saline, dextrose-based 

solutions, not likely to designate as dangerous waste

contact obtained data from Pyxis system, 189.3 liters over 13 days

53

to sanitary sewer

injectable one cc / two weeks 

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Commentsinjectable anesthetics Ketamine/valium 99+% and 

Propathal

0.5 ml/day 

Goes into the sink

Injectables only heparin and IV iron may 

typically become waste

estimated at much less than 15 cc/day of total injectables; assumed 15 for estimate below: 15 ml/day x 365 day/yr = 5475 ml/yr

expired meds once every 6 months 24 oz goes 

down the drain

some expired meds go overseas

Leftover narcotic 10 cc per month discharged into the linens, when linens are laundered the drug goes down the drainPartial injections Demerol maybe once per month into the sinkPresser, nurse's station IV liquids that regulate blood 

pressure

10 bags (250 cc each) per day 9

All solutions except chemo go to the sanitary sewer. Emptied debris goes to solid waste

expired samples usually liquids she really couldn't give me a 

number. But she agreed that it was probably once a month they would have some liquids they would flush down the toilet. I will assume the smallest number 1 ml even though this is a huge facility

liquids narcotics 10 cc per year narcotics are "wasted" down the drain

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Comments

Count of wastestreams generating this quantity: 18 Subtotal 

1

pills 10 doses per year dissolve down the drainantibiotics 5 to 10 pills/quarter Destruction policy: Immediate destruction to toilet if expired at quarterly reviewsamples and pills 25 boxes of four pills each Pills Unused expired pills less than 25 per year Most unused pills are sent back to the pharmacy before the expiration date to avoid waste. If expired, pills go down the drain.expired samples and pills 2000 in last four months Samplesexpired samples about once every 6 months they 

hve 12 or less pills. They crush the pills, soak them in water and put down the drain

Count of wastestreams generating this quantity: 6 Subtotal 

In the trash

Betadyne disinfectants spray bottles used, disinfectant 

wiped up with rags

"no waste" however, waste rags are going into the garbage

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition CommentsChemo, <3% If chemo remaining in container is 

< 3% of the total waste, it goes to solid waste. Site referred to this as the bag factor.

contact to compile data from Pyxis computer system; most chemo waste is managed this way

Count of wastestreams generating this quantity: 2 Subtotal

debris IV tubing, syringes one IV tubing/syringe/gloves, etc., 

per month

sometimes into biohazards, though

Count of wastestreams generating this quantity: 1 Subtotal 

narcotic 1 cc ev 3 months 

Count of wastestreams generating this quantity: 1 Subtotal 

pills outdated samples 20 pills every 6 months they crush pills before they throw in the trashpills about once every 6 months we 

have 6 bills we throw in the garbage

expired meds about every 6 months they have 3 

or 4 boxes of pills (5 pills in ech box average) that expire. We throw them in the garbage

Tablets/pills Tablets/pills 6 tablets or pills per year Most pills returned to distributor or manufacturer, so only a few go in the trash.

Count of wastestreams generating this quantity: 4 Subtotal 

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition CommentsChlorhexidene Disinfectant/irrigant for wounds, 

absorbed with surgical scrubs or sterile gauze

3 cups per year plus debris (assumed 3 cups weighed 2 pounds and debris weighed 2 pounds)

pills and tablets expired OTC and Rx products Products not returned to reverse 

distributor estimated to be 3 pounds per month - gross weight

Count of wastestreams generating this quantity: 2 Subtotal 

Into biohazard container

sharps/biohazards injectable antibiotics, hormones, anethetics no meds disposed, only sharps

multidose vials from which amounts are taken as needed until used up. All med in syringe is used.Chemo Chemotherapy drugs for animals, 

not a common vet procedure because pet owners often can't afford treatment.

Very small quantity

All chemo waste disposed in "Chemo" containers and routed as biohazardous waste for incineration.

gloves, gowns and plastic this is the majority of our waste - 

no quantity information given

samples/pills Guide unable to estimate aste 

volume of samples and pills generated by three physicians and one physician assistant

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition CommentsChemo Chemotherapy drugs for animals, 

not a common vet procedure because pet owners often can't afford treatment.

Very small quantity

All disposed in Chemo containers and routed as biohazardous waste for incineration.

Chemo Chemotherapy drugs for animals, 

not a common vet procedure because pet owners often can't afford treatment.

Very small quantity

All disposed in Chemo containers and routed as biohazardous waste.

Chemo Chemotherapy drugs for animals, 

not a common vet procedure because pet owners often can't afford treatment.

Very small quantity

All disposed in Chemo containers and routed as biohazardous waste.

samples from reps (pills) receptionist was unable to 

estimate the amount

packaging and pills are disposed of together in the biohazards container, which is shipped off to main clinic in Renton and disposed of as biohazard.ampoules partially used no datagoes into biohazard container and gets collected by stericycleother, mostly gloves most of our waste

Count of wastestreams generating this quantity: 10 Subtotal

Empty syringe no meds in syringes, generated 

during flu season

2,500 per year 

Goes to Stericycle

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition CommentsIV debris IV meds and debris. All the meds 

are used up

debris waste goes 2 doses per month into biohazard

debris IV tubing, syringes one IV tubing/syringe/gloves, etc. 

per month

sometimes in the trash, though.Hg thermometers 2 thermometers per year 

Count of wastestreams generating this quantity: 4 Subtotal 

syrup one pint/month injectable anesthetics narcotics, Propofol, Versed Average approximately 3 cc per 

patient, range 2-5 cc's". 3 ml/pt x 250 pt/mo x 12 mo/yr = 9000 ml/yr

collected in sharps container and sent to Stericycle

ointment/lotion most are outdated samples about one cup per month liquids 2 cc per year injectables DHE - single-dose vials no drug waste - drug all used up. 

Just the syringe

just the syringe, empty

injectables diuretics, fluids Guide said rarely administer IVs or 

injections. Estimate IV fluids at 1000 cc/month; injectables at 5 cc/month

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Commentsinjectable lidocaine 2 cc lidocaine left in syringe / 10 

vasectomies a month

sharps/biohazards 

injectable antibiotic 10 cc week injectable expired injectables 100 cc year injectable 1 cc ev 3 months antibiotics about once a month they have 1/2 

ml of waste

vaccine about once a mnoth they have 1/2 

ml of waste

unused injections once every 2 to 3 months they 

have about 1 cc of waste injection to put into sharps container

Oral solids and unused injectables

Bottles of pills are emptied into the biohazard container located in the pharmacy. Empty pill bottles go in regular garbage. Unused injectable liquids in vials also go into the pharmacy biohazard container.

One gallon container filled every 6 months.

Goes to Harborview Medical Center Purchasing, and ultimately disposed as dangerous waste.

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition CommentsUsed injectables About once a month, an individual 

dose is withdrawn from a septum vial of injectable drug that is less than the total amount in the vial. The left-over liquid (about 1 cc) in the vial is disposed into the biohazard container with the used injection sharp. Sometimes the pharmacist adds used sharps/vial waste from teaching patients selfinjection.

One cc in one vial per month 

Goes to Harborview, ultimately goes to BFI biohazardous waste.

injectable 0.5 cc 2c/wk injectable anesthetic 1.5 cc twice a week vaccines about once a month they have 1/2 

ml of vaccine they have to waste

Count of wastestreams generating this quantity: 18 Subtotal 

pills (samples) pills-samples 6 to 10 a year in the 

biohazard

only takes samples of things he can use. Uses them up - rarely expire. Has and would dispose of them in the red bag.

pills mostly outdated samples about 20 per month pills/powder 10 doses / month The biohazards go out with associated adult clinic and lab biohazardous waste

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Commentsexpired samples about every month there are 2 

boxes of pills in bingo cards, around 6 pills in each bingo card

pills 5 pills per year 

Count of wastestreams generating this quantity: 5 Subtotal 

Oral drugs Most are packaged for individual 

doses, most in "bingo cards" and some in resealable bags labeled for a particular patient, several are antiviral drugs

cardboard box lined with red bag, about 1/2 drum size (25 gal) is filled every 2 weeks; estimated weight includes packaging

Goes to Richard with Biohazardous waste, marked for incineration at Stericycle

Count of wastestreams generating this quantity: 1 Subtotal 

In a collection bin

oral solids expired birth control and allergy 

pills

20 or 30 per month 

Stored in several biohazard boxes, but not disposed of yet. We don't know what to do with it.

Count of wastestreams generating this quantity: 1 Subtotal 

Back to 

pharmac

y

one dose one dose, between five and ten 

ccs every six months

back to Swedish Hospital pharmacyLiquids Typical wastes are cough syrup 

and lidocaine.

cough syrup 240 ml/yr other (e.g., lidocaine) 100 ml/yr.

Back to PacMed Pharmacy - Beacon Hill, or back to Dept. of Health (vaccines). Cough syrup only goes to biohazard.

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Comments

Count of wastestreams generating this quantity: 2 Subtotal 

Reverse distributor

pills, tabs, etc. no quantity information giventhrough central officeOral solids Antibiotics and other pills or tablets initially said that 1% of the time, 

waste may be generated; however, contact checked Pyxis records and all oral solids were returned to reverse distributor, but no quantity data was available

More expired drugs at this site go to reverse distributor than at other hospitals observed.OTC over-the-counter drugs expired drugs go to reverse 

distributor, don't generate waste OTCs

samples two physicians give out about 90% 

of samples, leaving 10% waste

quantity of sample waste is unknown

OR drugs Anesthetics, controlled 

substances, and other drugs used in surgery

contact to compile data from OR records

PS Industries picks up the waste

all wastes oral solids, injectables, topicals 

and oral solutions, even dropped tabs

no waste, all, even dropped tabs, returned

All, even dropped tabs, are returned

Narcotics DEA controlled substances contact to compile data from Pyxis 

computer system

PS Industries picks up the waste

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Comments

Count of wastestreams generating this quantity: 7 Subtotal

tabs & pills 125 pills/week 

Count of wastestreams generating this quantity: 1 Subtotal 

Narcotics C-II 45.28 grams over 5 months pills and tablets All expired, unused, partial and full 

pharmaceuticals

Eight boxes (18" square) weighing an estimated 20 pounds each are collected from the 54 Bartells stores

pills & tabs miscellaneous dropped and 

unidentified pills and tablets

From all 54 stores, eight liters of misc pill are collected, each liter weighing about two pounds

The pharmacy recognizes it will not receive credit for these items, but doesn't know how to deal with them otherwise and does not want to contaminate the water or soil.

Count of wastestreams generating this quantity: 3 Subtotal 

HW Vendor

Chemo Chemotherapy drugs in solution in 

a vial or in a bag

10 gallons per week 19

Goes to Richard with Environmental Services (not BioHazard)

Count of wastestreams generating this quantity: 1 Subtotal 

Chemo, >3% If chemo remaining in container is 

>3% of the waste, it is collected as hazardous waste.

data compiled from Pyxis computer system; 995 pounds for 9 months (unclear whether this is total waste or active ingredient, assumed it was total waste).

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition CommentsChemo, >3% If chemo remaining in container is 

>3% of the waste, it is collected as hazardous waste.

385 pounds per 9 months (assumed this is total waste)

tabs/caps/vial/inj/patches/otic, etc.

controlled substances regulated by DEA

241 pounds in nine months (after packaging removed, and includes basic container packaging)

Chemo, >3% If chemo remaining in container is 

>3% of the waste, it is collected as hazardous waste.

25 pounds per 9 months (assumed this is total waste)

IV solns/oral solns/lg vials, etc.

controlled substances regulated by DEA

881 pounds over a nine month period (packaging removed, and includes basic container packaging

tabs/caps/vials/inj/patches/otics, etc.

legend drugs 151 pounds (after packaging 

removed, and includes basic container packaging) over a ninemonth period

IV solns/oral solns/lg vials, etc.

legend drugs 27 pounds (packaging removed, 

and includes basic container packaging) over a nine-month period

Count of wastestreams generating this quantity: 7 Subtotal 

Other - describeTuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Commentspills samples shared by three doctors; 

less than 5% of samples are wasted

most are donated to very small quantity <5%free health clinics or church organizations. A few go to the sewer.

Class 2 Narcotics expired no idea; person questioned said he 

purchases for 80 different doctors and clinincs, but has nothing to do with disposal

DEA-licensed vendor who incinerates everythingAll returned to Tablets/pills Tablets/pills none disposeddistributor or manufacturer or donated to free care clinics

Count of wastestreams generating this quantity: 3 Subtotal

vaccine sharps Occasionally a vaccine might 

expire, but it's very rare. We don't keep anything in stock - very few injections. We order only the amount we need and send expirations to the pharmacy. We dispense meds through AllScript. We have multidose vials of Lidocaine, but use them up and have no waste. We also have some Neosporin, an antiflammatory.

sharps container 

Note conflict: expired meds go to pharmacy, but expired vaccines go into sharps container.

Count of wastestreams generating this quantity: 1 Subtotal 

to MD that does injectable 5 cc ev 6 months missionary work in 3rd world countries

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Comments

to MD that does liquid inhaler 50 cc ev 6 months missionary work in 3rd world countriesWorld Concern expired IV meds one sandwich-sized Ziploc bag 

Count of wastestreams generating this quantity: 3 Subtotal 

to MD that does pills 10 pills ev 6 months missionary work in 3rd world countries

samples I check the samples about every 3 

or 4 months. I find about 10 samples that have expired. They have 1 or 2 pills in each sample

return to vendor 

expired pills one of the doctors take the expired 

pills to Latvia. Also they have in the past sent some to World Concern. I got her to give me a range and she agreed to "more than a dozen in a year" I will assume that each packet contains 4 pills 4 x 13 = 52

other countries 

All returned to Tablets/pills Tablets/pills none disposed distributor or manufacturer or donated to free care clinics

expired samples there is about 1 pill per packet and 

we have maybe 5 pills per year

they save and occasionally someone calls who is going to a 3rd world country and takes them

they haven't had anyone call for a while

Tuesday, November 12, 2002 
Waste Goes: Waste Name and Description Generation Rate Description Qua

per 

Disposition Comments

All returned to Tablets/pills Tablets/pills none disposed distributor or manufacturer or donated to free care clinics

oral solids neurology clinic - pills only on site 

in bingo cards

20 to 50 pills in bingo cards every three months

the drug sales rep takes them

don't know what rep does with them

All returned to Tablets/pills Tablets/pills none disposed distributor or manufacturer or donated to free care clinics

oral solids estimated at 100 mg each 25 tabs or caps / year, each tab = 

100 mg, 2500 mg/year

undisclosed 

do these go back to reverse distributor? If not, where are they disposed?

any expired pills one or two doses one or two doses (pills) per month vaccines go back to the Health Dept. Nothing goes to the red bag.

Count of wastestreams generating this quantity: 10 Subtotal 

Tuesday, November 12, 2002 
 

King County - Pharmaceutical Waste Survey 89 

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22, 2002. 

Morrison, Richard D. Drug Distribution in Washington. Washington State Board of Pharmacy. 

Presentation to Medical Industry Roundtable, Seattle, WA: May 15, 2002. 

United States. 1997 NAICS Matched to 1987 SIC-Health Care and Social Assistance. United 

States Census Bureau. Washington , DC: 1998 

<http://www.census.gov/epcd/naics/NAICS63.htm > 10/14/02. 

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<http://www.randomizer.org/> 10/11/02. 

Washington Department of Social and Health Services. Directory of Nursing Homes, Last 

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<http://www.aasa.dshs.wa.gov/Professional/NFDir/directory.asp> 10/10/02. 

Washington State Department of Ecology. Dangerous Waste Regulations Chapter 173-303, 

Washington Administrative Code as Amended June 2000. Publication No. 92-91. 

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