Search

Managing P-List Hazardous Wastes in Satellite Areas

Posted on 4/5/2016 by Roger Marks

In a February 17, 2016, letter to industry, US EPA clarified a critical point of waste management for the pharmaceutical industry and other hazardous waste sites that manage commercial chemical products, or CCPs.

Some major pharmaceutical products meet the criteria of an acute hazardous waste, like Warfarin (a P001 waste at concentrations greater than 0.3%), nicotine gums and patches, and others. When pharmacies and medical facilities use or dispense these pharmaceuticals, residue may remain in the containers (bottles, blister packs, etc.). This residue is a P-listed acute hazardous waste.

This affects sites that store these hazardous wastes in two major ways:

First, any facility that generates more than 1 kg of an acute hazardous waste in one calendar month is a large quantity generator under RCRA. Large quantity generators, or LQGs, are subject to the most stringent hazardous waste management requirements, including an annual training requirement for hazardous waste personnel.  

In addition, US EPA sets a strict limit on the volume of acute hazardous waste that can be held in a satellite accumulation area. Generators may keep up to 1 quart of acute hazardous waste in a satellite area. [40 CFR 262.34(c)]

EPA Guidance on Counting Acute Hazardous Waste
The question asked of EPA was this: Do the containers—like pill bottles and blister packs—count toward the quantity limit for satellite accumulation areas?

To answer this question, EPA points to a November 2011 letter (RO 14827) in which it clarified that only the residue itself must be considered toward a site’s hazardous waste generator status, not the containers that contain the residue. EPA expands on this point to state that the same principle applies to satellite accumulation areas: Only the residue within the container should be counted toward the 1-quart limit, not the containers themselves.

See the February 2016 EPA letter here.

EPA’s New Rules for Hazardous Waste Pharmaceuticals

Last year, US EPA proposed new standards for managing hazardous waste pharmaceuticals under a new 40 CFR Subpart P. The long awaited new rules for hazardous waste pharmaceuticals include notification requirements, a new category of pharmaceutical facility, standards for counting pharmaceutical hazardous waste, and RCRA training requirements for personnel at healthcare facilities. Read about EPA’s rules for hazardous waste pharmaceuticals here.

p list RCRA hazardous waste pharmaceuticals
What Are Satellite Accumulation Areas?

Satellite accumulation areas are areas of a facility where waste is initially collected and temporarily stored, before being eventually moved to a central accumulation area for management under 40 CFR 262.34

What’s the P List?

The P List refers to the list at 40 CFR 261.33(e) of commercial chemical products listed as hazardous waste due to their acute hazard(s). A “P-listed chemical” is a chemical that is listed as hazardous waste and assigned a P### code by 40 CFR 261.33.  

Questions about using RCRA waste codes? Read Simplifying Your Approach to Waste ID.

RCRA Training for Experienced Professionals

Get up to speed with the latest RCRA rules for managing your site’s hazardous waste from cradle to grave under US EPA’s 40 CFR regulations. At the RCRA Hazardous Waste Management Refresher Webinar, meet your annual refresher RCRA training requirement and build a step-by-step approach to keeping your personnel safe and your waste containers in compliance. 

Presented live by a full-time Lion instructor, this RCRA refresher webinar blends the convenience of online training with the trusted RCRA curriculum covered in Lion’s nationwide public workshops. Sign up today to fulfill your annual training mandate and protect your site from EPA fines up to $37,500 per day, per violation. Enrollment includes a full year Membership for regulatory updates, support, and exclusive content.

Tags: EPA, hazardous waste

Find a Post

Compliance Archives

Lion - Quotes

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

I have been to other training companies, but Lion’s material is much better and easier to understand.

Mark Abell

Regional Manager

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

No comparison. Lion has the best RCRA training ever!!

Matt Sabine

Environmental Specialist

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

The online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.

Francisco Gallardo

HES Technician

Download Our Latest Whitepaper

Look beyond the annual "Top 10 List" to see specifics about the most cited OSHA health & safety Standards and the individual regulations that tripped up employers the most last year. 

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.