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EPA updates rule prohibiting improper disposal of pharmaceutical hazardous waste

July 16, 2019

By David Burger

Washington — Dental facilities and other health care businesses that generate pharmaceutical hazardous waste are required to manage those products according to the provisions of a rule that goes into effect Aug. 21, according to the ADA Council on Dental Practice.

The finalized rule prohibits health care facilities from disposing of pharmaceutical hazardous waste by pouring them down drains or into sewers in a practice commonly known as “sewering.”

Dr. Van Scoyoc
The EPA issued the rule — called the Environmental Protection Agency’s Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine Final Rule — to make it easier for the health care industry to manage the proper disposal of hazardous waste disposal and to protect human health and the environment, said Dr. Stacey K. Van Scoyoc, chair of the Council on Dental Practice.

“Banning the drain disposal of hazardous waste is expected to keep between 1,644 and 2,300 tons of pharmaceutical waste out of the environment every year,” Dr. Van Scoyoc said. “As a result, the EPA anticipates that the rule will lessen the negative effect of hazardous waste pharmaceutical on aquatic ecosystems and on fish and animal populations.”

The rule applies to all health care facilities and reverse distributors that generate and manage hazardous waste pharmaceuticals. Dental providers are specifically mentioned as one of the categories of providers required to abide by the rule

“While it’s impossible to provide a single comprehensive list that details every item covered under the new rule, the EPA has determined that a large portion of the pharmaceutical wastes generated at health care facilities will not meet the definition of a hazardous waste,” said Dr. Van Scoyoc. “Dentists should know that dental amalgam and sharps are not classified as pharmaceuticals under the rule and that the rule does not add any new pharmaceuticals to the universe of regulated hazardous waste.”

Sewering is already banned or severely limited in some states and it’s possible that other states will enact similar prohibitions.

“Be aware that states may have more restrictive rules for the disposal of non-hazardous materials with requirements beyond what is found in the EPA’s rule so it’s prudent to review your state’s specific requirements to determine whether they’re more stringent than those at the federal level,” Dr. Van Scoyoc said.

According to Dr. Van Scoyoc, the council has developed an FAQ, available at, to assist dentists in understanding the final rule. That resource also provides details on what practices need to do to comply, the possible penalties for failing to comply with the rule, and links to several helpful federal resources that can provide more information.

For more information, please contact the Center for Dental Practice at or 1-312-440-2895 or the toll-free number for ADA members.