Healthcare: New MA DEP Medicinal Nitroglycerine Regulation

by Matt Teeter, Healthcare Environmental Compliance Advisor

Currently in the Commonwealth of Massachusetts, medicinal nitroglycerine is collected as an acutely hazardous waste; per the Massachusetts DEP it exhibits reactive hazardous waste characteristics therefore requiring it to be treated as a P081 listed waste. The Commonwealth has not yet adopted the US EPA standpoint that medicinal formulations of nitroglycerin are no longer considered P-listed waste because it is in a diluted form and therefore non-reactive.

Currently in Massachusetts, empty medicinal nitroglycerine containers either need to be triple rinsed and the rinse water collected as hazardous waste, or empty vials and ampoules must be collected and treated as hazardous waste. Included in the new Massachusetts DEP amendment, empty containers not exhibiting hazardous waste characteristics will be able to be disposed of as non-hazardous waste.

As of May 1, 2009 the Massachusetts DEP will be amending 310CMR 30.104 to list medicinal nitroglycerine in finished dosage forms (i.e. tablets, patches, IV's, creams and/or capsules), that do not exhibit hazardous waste characteristics to no longer be P-listed wastes and may be disposed of as a non-hazardous waste. The 310 CMR 30.104 amendments read as follows:

"Medicinal nitroglycerine, in finished dosage form such as tablets or capsules, that would otherwise meet the description of a P081 listed waste, is not subject to hazardous waste regulation pursuant to 310 CMR 30.000 so long as, upon generation, the following conditions are met:

  1. The waste does not meet the description of any other listing; and
  2. The waste does not exhibit any hazardous waste characteristic; including the characteristic for which it was originally listed (i.e. the reactivity characteristic, as described at 310 CMR 30.124)."

Most hospitals that have implemented a pharmaceutical collection program are already collecting nitroglycerine, and may decide to continue the collection of this material under their environmental stewardship program. If a hospital should choose to do so, nitroglycerine would not have to remain on the hazardous waste label, but would stay on the disposal profile and not carry the "P" code. As such it would not be counted towards a generator's status as a small or large quantity generator of hazardous waste. Removing the "P" code may make it easier and more favorable to manage this waste stream for outlying patient care areas.

For questions, please contact Healthcare Account Managers Steve Todisco or Bryan Soltysik.