Doctor’s offices and hospitals are bound to end up with expired medications. However, as with many items that constitute medical waste, you cannot simply throw those medications in the trash. Rather, they must be properly disposed of. The process can be confusing, as not all expired medications are required to be stored, packaged, or treated in the same way.

01   /   About Expired Medications

Some may believe that an expired medication is inert or harmless. However the expiration date is merely a data point that a drug manufacturer uses to ensure that the drug maintains full potency. Expiration dates are found on prescription, over-the-counter- and herbal supplements. Expiration dates are required on all prescription and most over-the-counter products.

While a pharmacy would not dispense a medication close to its expiration date, be aware that the components found in some medications can be active anywhere from 1 to 5 years past that expiration date. That said, it is important that any expired medicine is properly disposed of for safety to the healthcare provider, the general public, and to the environment.

For these reasons, it is vital to comply with all federal and state regulations in regard to medication/pharmaceutical disposal processes, based on the type of medicine: hazardous or non-hazardous. The protocols for disposal are dependent on the different categories of expired medications. Knowing how to dispose of expired medication properly constitutes a large part of safe medical waste disposal.

02   /   Medications and Red Bags

Red bags are exclusively used for regulated medical waste - items that have been in contact with or contaminated by blood, blood components or other potentially infectious materials. Medications do not qualify under the definition of regulated medical waste, but this is where it can get confusing, as a discarded pharmaceutical can be deemed biohazardous. That said, no pharmaceuticals should be disposed of as red bag waste, nor should expired medications, prescription or not, potentially hazardous or not. Putting expired medication in red bag waste constitutes a violation of the regulations related to proper waste disposal.

Red bag waste is intended exclusively for gauze, gloves, contaminated sharps, and all other items that have come in contact with blood or other materials that have the potential to spread blood-borne pathogens.

03   /   Why Shouldn't Waste Medication be mixed with Regulated Medical Waste?

Regulated red bag waste and medicinal or pharmaceutical waste are disposed of or destroyed by different methods because they are different types of waste. All red bag waste is treated with a sterilization process called autoclaving. This essentially uses a large oven that's heated to approximately 250 to 300 degrees. This waste stream is exposed to such high temperatures for specific time frames, depending on type, volume, and size of the autoclave. Timing ranges from a few minutes to an hour, again depending on the waste.

The autoclave process kills bacteria or other harmful or potentially infectious components in that red bag waste that renders it harmless before it is then transported to a landfill and disposed of.

Due to different components in drugs or pharmaceuticals, such as antibiotics, the autoclave process is not effective in ‘killing’ or ‘denaturing’ those components and rendering them inactive or harmless.

Medications, expired or not, must be incinerated. If an expired medication or a sample medication is tossed into red bag waste, those medicines will only be exposed to the autoclaving process, which is not sufficient to properly denature the medications. Hazardous medications will therefore remain hazardous, which obviously poses a safety and environmental risk.

Improper disposal and treatment such as this also puts your office or facility out of compliance with federal regulations. Non-compliance can result in huge fines and penalties for any facility found to be improperly disposing of expired or non-expired medications.

Again, whether expired or not, it is also important to know the difference between a hazardous and a non-hazardous medicine. Hazardous medicines are regulated by state and federal agencies, though non-hazardous drugs are not. Also be aware of the difference between a controlled substance and a hazardous one.

Even a non-hazardous medicine (expired or not) can have a negative impact on the environment. It call comes down to its chemical properties. Visit the Environmental Protection Agency for more information on management of hazardous waste pharmaceuticals here.

Every state has their own rules for pharmaceutical waste disposal as well, which can typically be accessed through their Departments of Natural Resources or Environmental Protection.

04   /   Proper Protocol for Disposing of Hazardous Medication

Medications that have been deemed hazardous waste (as established by Resource Conservation and Recovery Act or RCRA) need to go into specialized incinerators. These run at much higher temperatures than autoclaves and turn hazardous medicine waste into nonhazardous waste.

Hazardous wastes are often identified by their characteristics, such as toxicity, flammability, corrosivity, or reactivity. As an example, a chemotherapy drug is deemed hazardous as it is toxic in nature. Most states apply the same guidelines as the RCRA, but it’s always a good idea to make sure to ensure your facility remains compliant.

It's the responsibility of the hospital, clinic, doctor's office, or facility to know what medications they deal with are considered hazardous under RCRA standards. Know the difference between hazardous and non-hazardous medications. Improper identification (and subsequent disposal) can contribute to serious environmental contamination as put your facility at risk for fines or other punitive action for non-compliance with medication waste regulations.

05   /   Protocol for Disposal of Non-hazardous Medications

If your office or clinic has expired non-hazardous medications, they must not be thrown into red bag or ‘regular’ office waste. Even non-hazardous medications need to be separately contained, stored, and disposed of. Expired and non-expired medicinal should be placed into separate containers (these are provided by a medical waste management company) to be shipped to proper treatment facilities.

Pharmaceutical waste containers come in a variety of sizes and should be labeled differently than bio-hazardous waste to clearly identify the contents as pharmaceutical waste. Different labels must be used depending on contents. The federal and state Departments of Transportation (DOT) also have rules for pharmaceutical transport off-site for incineration prior to disposal.

06   /   Rely on a Reputable Waste Management Company for Drug Disposal

An experienced and full-service medical waste management company can review your formulary and ascertain for you what you have that's hazardous. They can also determine if the chemicals within certain non-hazardous items will become hazardous if combined or brought into contact with each other.

If you're at all unsure or confused about this process, then this highly technical job is best left to a medical waste management company and their trained, knowledgeable professionals who know exactly what they're looking for and how to handle, classify, containerize, transport, and dispose of hazardous medications.

For more information about how to properly dispose of expired (or non-expired) medications, contact a representative of MCF Environmental Services, a full-service medical waste management company with over three decades of experience in medical, industrial, and hazardous waste management and disposal.

Robert Losurdo

President, COO