Full Document:
RCRA Online Number: 14919
Title: Manifesting Non-Creditable Hazardous Waste Pharmaceuticals - New Four Character Code
Document Date: 2019-12-19
To: Land, Chemicals and Redevelopment Division Directors
From: Johnson
Organization of Recipient: EPA
Description: Both PHARMS and PHRM are acceptable codes to use on the hazardous waste manifest when shipping non-creditable hazardous waste pharmaceuticals from a healthcare facility that is operating under 40 CFR 266 subpart P. The regulations in subpart P require healthcare facilities to input PHARMS in Item 13 of the manifest. However, implementing agencies and the regulated community expressed difficulty using a six-character code. To address this issue, EPA developed the four-character PHRM code. This memo also clarifies that additional waste codes may be included on the manifest along with the PHRM/PHARMS code, but additional codes are not federally required.
Regulatory Citation(s): 266.502(a)(2)(ii), 266.508(a)(2)(i)
Official ORCR Policy: Yes
Associated Topic(s):
Compliance,
Disposal,
EPA Forms,
Generators,
Hazardous Waste,
Manifest,
Transporters |