QUESTION: Recently, I heard that outdated vials of epinephrine and epinephrine pens require special disposal because epinephrine is a hazardous substance. If this is true, what should I do with outdated epinephrine-containing products in the OR?

ANSWER: Epinephrine is a regulated hazardous waste that must be disposed of according to the Environmental Protection Agency's (EPA's) Resource Conservation and Recovery Act (RCRA) regulations. (1) Although, these rules were created in the mid 1970s, health care facilities were not required to adhere to them until recently. Approximately four years ago, the EPA began inspecting hospitals and assessing fines for RCRA violations. For example, one large hospital on the East Coast was fined $214,420 (2) and another was fined $372,254 (3) for hazardous-waste disposal violations.

In the RCRA regulations, chemicals are considered regulated or nonregulated rather than hazardous or nonhazardous. The EPA defines regulated waste as being either characteristic waste or listed waste. According to EPA definitions, characteristic wastes are those that are ignitable, reactive, corrosive, or toxic. Listed waste chemicals are placed in one of four lists: F, K, U, or P. (4)

* F-listed wastes are generic process wastes from nonspecific sources. (5)

* K-listed wastes are industry-specific wastes from specific sources. (6)

* U- and P-listed wastes are discarded commercial chemical products. (7,8)

Epinephrine is a P-listed waste, meaning that it is considered a highly toxic or acute hazardous waste. All P-listed wastes are wastes in which the sole active ingredient is the listed chemical. This is the only EPA waste type for which empty containers also must be treated as hazardous waste. If the P-listed chemical is not the sole active ingredient, then the chemical does not require special disposal. For example, in the medication lidocaine with epinephrine, both the lidocaine and the epinephrine have active purposes; therefore, epinephrine is not the sole active ingredient, and the substance is not regulated as hazardous waste. The rules apply to

* unused, discarded commercial chemical products (eg, outdated never-opened vials of epinephrine);

* off-specification chemicals (eg, epinephrine that contains impurities);

* container residue (eg, empty original containers, although the EPA has specifically exempted residues left in a syringe or other dispensing instrument.  Medical Supplies.