Non-Creditable HWP’s Simplified
Under EPA’s Subpart P, they define a non-creditable hazardous waste pharmaceutical (NCHWP) as a hazardous waste pharmaceutical that cannot be sent back to the reverse distributor as it has no potential to receive credit.
- Hazardous Waste Pharmaceutical (and)
- NO reasonable expectation of credit (or)
- Examples: Damaged, leaking, samples, investigational drugs, repackaged pharmaceuticals, compounded drugs, floor sweepings, contaminated PPE, etc.
- Fails any one of the PCHWP criteria – see blog “Potentially Creditable HWP’s Simplified”.
Disposal of NCHWP’s must be done by a TSDF (hazardous waste incinerator). We have designed compliant mail back programs specifically for NCHWP’s generated by healthcare facilities.
If you are operating under Subpart P, there are specific management requirements for NCHWP’s that can be found at 40 CFR Part 266.502. These requirements address the issues of: EPA notification, training, container standards, storage, labeling, accumulation, exception reporting, record-keeping, shipping, land disposal, manifesting, spill response, rejected shipments, commingling, unsuitable for incineration, disposal confirmation.
Of course, a VSQG (Very Small Quantity Generator) can opt not to participate under EPA’s Subpart P if certain conditions are met.
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