Memo Detail

Full Document:PDF Link
RCRA Online Number: 14788
Title: EPINEPHRINE SYRINGE AND EPINEPHRINE SALTS
Document Date: 2008-04-14
To: Chilcott
From: Dellinger
Organization of Recipient: Sure-Way Systems, Inc.
Description: The 1994 epinephrine syringe interpretation states that the residual epinephrine contained in a used discarded syringe is no longer classified as a listed hazardous waste. This interpretation does extend to other P- and U-listed pharmaceuticals administered by syringe. If residue remaining within a needle and syringe exhibits a characteristic, the needle and syringe would need to be managed as a RCRA hazardous waste. This interpretation only applies to syringes. The Agency has recently clarified that epinephrine salts are not included in the epinephrine PO42 listing. Therefore, epinephrine salts and all delivery devices which contact them would be hazardous only if they exhibited one or more of the hazardous wastes' characteristics [SEE ALSO: RO 14778].
Associated Topic(s): Hazardous Waste Identification