In this guide
- What is RCRA Subpart P?
- Which drugs are hazardous
- What facilities must do
What is RCRA Subpart P?
Subpart P (40 CFR Part 266) is the EPA’s Management Standards for Hazardous Waste Pharmaceuticals. It sets how healthcare facilities and reverse distributors must handle RCRA-hazardous pharmaceutical waste — and, critically, it prohibits sewering (flushing) hazardous pharmaceuticals down the drain.
Which pharmaceuticals are RCRA-hazardous?
Three categories:
- P-listed — acutely hazardous (warfarin above certain levels, nicotine, epinephrine, physostigmine)
- U-listed — toxic pharmaceuticals and residues
- Characteristic (D-codes) — ignitable, corrosive, or toxic drugs
Common surprises: nicotine (P075) and warfarin are P-listed acutely hazardous waste, not regular trash.
What Subpart P requires of facilities
- Identify and segregate hazardous pharmaceutical waste
- Use labeled, closed, leak-proof containers
- Never sewer (flush) hazardous pharmaceuticals
- Manifest and ship to a permitted destruction facility
- Keep documentation and Certificates of Destruction
Frequently asked questions
What is RCRA Subpart P?
It's the EPA's Management Standards for Hazardous Waste Pharmaceuticals (40 CFR Part 266), governing how facilities and reverse distributors handle hazardous drug waste — and it prohibits flushing them.
Which pharmaceuticals are RCRA-hazardous?
P-listed acutely hazardous drugs (warfarin, nicotine, epinephrine, physostigmine), U-listed toxic drugs, and characteristic D-code drugs (ignitable, corrosive, toxic).
Is nicotine really hazardous waste?
Yes — nicotine is P075, an acutely hazardous P-listed waste. Certain nicotine products must be managed as RCRA-hazardous waste, not trashed.
Does Subpart P ban flushing medications?
Yes — sewering (flushing) hazardous pharmaceuticals is prohibited under Subpart P. They must be containerized, manifested, and destroyed at a permitted facility.
Keep reading
Is Warfarin Hazardous Waste? P-Listed vs. U-Listed Disposal
Warfarin is P001 above 0.3% and U248 at or below — how to classify and dispose of it under RCRA.
Read guide →RCRA HazardousRCRA Hazardous Waste Container Requirements (Black Containers)
The black container, labeling, closed-and-compatible rules, accumulation limits, and dating under Subpart P.
Read guide →RCRA HazardousHow Pharmacies Dispose of Hazardous Waste (RCRA Guide)
The hazardous drugs on your shelf, generator status, Subpart P obligations, and the setup that passes inspection.
Read guide →