[Pharmwaste] EPA interpretive memo regarding epinephrine salts

Bunnell, Ross Ross.Bunnell at po.state.ct.us
Thu Nov 15 11:49:28 EST 2007

Dear PharmWaste ListServe members:

I suspect many of you have already seen the memo referred to above (it's
been circulating around on other listserves), but for those of you who
haven't, you can access it at:


It's basically a memo from EPA indicating that the P042 hazardous waste
listing for epinephrine covers only base epinephrine, and not
epinephrine salts.  If states decide to follow this policy, this could
have the effect of de-regulating a significant portion of pharmaceutical
epinephrine generated in the health care industry.

This memo is similar to one prepared by the State of Colorado, which is
available at:


QUESTION:  Any opinions out there about this policy interpretation?  Is
this a good thing in that it will result in fewer health care facilities
being regulated as large quantity generators of hazardous waste?  Or is
it a bad thing in inappropriately letting a lot of rather toxic material
escape regulation?

Well, whattaya think??

- - Ross Bunnell, CT DEP
Bureau of Materials Management and Compliance Assurance
Waste Engineering & Enforcement Division
79 Elm Street
Hartford, CT 06106-5127
Tel. (860) 424-3274  Fax (860) 424-4059

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