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Waste	Management	Recommendations	on

Disposal	of	Consumer	Unused	Medications

February 11, 2011

Goals	of	a	Comprehensive	Consumer	Pharmaceutical	Take-back	Program

The ideal program will be:

1. Convenient

2. Safe (both from a physical and a diversion perspective)

3. Cost-effective

4. Widely Available 

Key program elements:

 Multiple drug return options, such as kiosk drop boxes in pharmacies and other 

convenient locations, mail-back containers, and community events for scheduled dropoff; 

 Use of existing transportation infrastructure, such as USPS, FedEx, and UPS to provide 

cost-effective logistics;

 Flexible disposal options that are compliant with federal and state regulatory 

requirements;

 Disposal of returned household pharmaceuticals by incineration at a permitted medical 

waste incinerator or MSW waste-to-energy facility will be significantly less costly than 

disposal at a hazardous waste incinerator;

 Appropriate state agencies should be tasked with development of regulatory criteria 

for program approval, performance and oversight to ensure that ultimate disposal is 

secure and environmentally protective; and

 Return options compliant with Federal Controlled Substances Act;

WM	has	recommended	safe	destruction	of	consumer	pharmaceutical	

discards	using	permitted	waste-to-energy	or	medical	waste	incineration. 

These methods are environmentally protective, ensure complete destruction, and are costeffective.

Take-back programs	will	only	be	successful	if	they	are	cost-effective, as	

funding	sources	are	limited.		Hazardous waste incineration will be significantly more 

costly and may discourage or impede the nascent consumer take-back or mail-back programs.

Hazardous waste incineration is about five times more expensive than waste-to-energy and 

about three times more expensive than medical waste incineration. (See Table of Comparative 

Costs on pg 4) Since only 8 hazardous waste incinerators are available, compared with 86

waste-to-energy facilities and 22 regulated medical waste incinerators, transportation and 

logistics costs are also higher for hazardous waste treatment. 
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If pharmaceutical take-back/mail-back programs are expensive, fewer consumers will 

participate and will continue to either drain dispose or stockpile unused medications.

Only	a	tiny	percentage	of	consumer	pharmaceutical	discards	would	even	

trigger	the	household	hazardous	waste	exclusion.	 Most materials in consumers’ 

possession are not hazardous wastes. Only about 5% of the drugs on the market meet the 

criteria for hazardous waste and a number of those, such as physostigmine, are only used in 

healthcare settings and not by consumers. Among controlled substances, the only drugs over 

which DEA has regulatory authority, only 2.6% are hazardous waste. Of these, two are listed, 

chloral hydrate, U034, used only in pediatrics in hospitals, and phentermine, P046, one of the 

diet drugs used in Fen-Phen, which is now seldom prescribed. The remaining drugs that 

become hazardous waste are D001 for alcohol content and include Paregoric, (camphorated 

tincture of opium) and two drugs in alcoholic preparation, diazepam (Valium) and testosterone.

In a review of data documented by the Texas Tech UHSC School of Pharmacy at an actual “takeback” community event, 646 lines of controlled substances were recorded, with 7 being 

hazardous waste (1.08%). For non-controlled prescription drugs, of 4571 recorded lines, 42 

were warfarin (.9%), 69 pressurized inhalers were counted (most were non-flammable) (1.6%), 

and 11 vials of human insulin were noted (.2%). In total 136 lines of potentially hazardous 

waste (including the non-flammable aerosols) was collected or 2.9% of the total non-controlled 

prescription drugs. 

Separating pharmaceutical discards to identify the tiny percentage that designate as hazardous 

waste would significantly increase the risk of theft and diversion as sealed containers would 

need to be opened and the contents handled by program staff.

Importantly, increased handling of discards poses occupational hazards, particularly if the 

contents of individual medicine containers are not well-labeled.

There	are	significant	differences	in	the	design	and	implementation	of	

pharmaceutical	take-back/mail-back	programs	and	household	

hazardous	waste	(HHW)	collection	programs. The vast majority of 

pharmaceutical take-back programs being piloted or under development do not envision 

accepting household hazardous wastes. In fact, many pharmaceutical collection program 

designs would utilize mail-back containers or locked kiosks in retail or office locations that are 

unsuitable for HHW.

Each year, there are approximately 3,000 HHW programs operating in the US either as limited 

events or as permanent collection programs. It is estimated that only a small portion of these 

programs accept pharmaceuticals. The small portion of household hazardous waste (HHW)

collection programs that do accept consumer discarded medications in many cases segregate 

pharmaceutical waste from HHW. The segregation allows the waste to be treated at a lower 

cost incinerator. A few HHW programs that collect pharmaceuticals from residents combine 
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the waste with flammable or toxic waste steams. Most HHW programs may not accept 

controlled substances because they typically do not involve law enforcement officers. 

Though less mature than HHW programs, the number of pharmaceutical collection events or 

take-back programs is increasing. The DEA sponsored with local law enforcement a national, 

one-day consumer pharmaceutical collection event in September of 2010 with participation 

from over 3,000 locations. The typical pharmaceutical take-back program or event collects and 

segregates only prescription and over the counter (OTC) medications. Many of these programs 

involve law enforcement and are able to accept controlled substances. 

Forty-three U.S. states do not regulate the prescription and OTC discarded material collected by 

these programs as hazardous waste. Of the seven states that do, at least two of the states (NH, 

WA) are considering a change that would exempt the waste stream from management as a 

state hazardous waste. A non-hazardous classification allows additional options for storage, 

transportation, and treatment of the waste lowering costs for program operators. 

WM	believes	consumer	pharmaceutical	take-back/mail-back	programs	

are	sufficiently	different	from	household	hazardous	waste	collection	

programs	that	they	warrant	EPA’s	consideration	of	different	disposal	

and	management	recommendations.
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PHARMACEUTICAL WASTE DISPOSALCOMPARISION 

Type of Facility

Waste-To-Energy Plant

Hazardous Waste 

Incinerator

Regulated Medical 

Waste 

Incinerator

Number of Facilities Nationwide 86 8 22

Types of 

Pharmaceutic

al Wastes 

Handled

Non-Hazardous Yes Yes Yes

Hazardous No Yes (permit dependent) No

Controlled Yes (non-RCRA C only) Yes (permit dependent) Yes

Regulated Medical No ?

Yes

Cost For 

Disposal 

(per ton)

Non-Hazardous $200 - $300 $1,200 - $1,600 $500

Hazardous Not Applicable $2,000 and up

Controlled $300 - $400 $2,000 and up $500

Regulated Not Applicable Not Obtained Not Obtained

Comments Concerning Costs

Costs are for typical pit feed. If 

hopper feed (regulated flow rate) 

is required, cost is $350 -

$800/per ton

Costs do not include EIS 

fees (typically 10%) or 

incineration taxes ($2 - $5 

per ton)

Additional costs applicable for 

special handling labor or 

destruction witnesses

Additional costs applicable 

for special handling labor or 

destruction witnesses

Additional costs applicable 

for special handling labor 

or destruction witnesses

Minimum per load cost = $500

Acceptable Packaging 

Cardboard boxes shrink wrapped 

and palletized, gaylords, poly 

drums, fiber drums, bulk. No 

metal drums

Cardboard boxes shrink 

wrapped and palletized, 

gaylords, metal drums, poly 

drums, fiber drums, some 

bulk containers.

Pharmaceutic

al Waste 

Definitions 

(used in cost 

section above)

Non-Hazardous - Include pharmaceutical packaged products, as well as, raw 

materials and waste from production of these products

Hazardous - Typically include listed (P & U listed) and characteristic (ignitability, 

corrosivity, reactivity, toxicity) waste

Controlled substances - Drugs (divided into 5 schedules based on potential for 

abuse) regulated by the Drug Enforcement Administration

Regulated - Liquid or semi-liquid blood or other potentially infectious materials; 

contaminated items that would release blood