Potentially Creditable HWP’s Simplified
Under EPA’s Subpart P, they define a potentially creditable hazardous waste pharmaceutical (PCHWP) as a hazardous waste pharmaceutical can be sent back to the reverse distributor as it has the potential to receive credit.
- Hazardous Waste Pharmaceutical (and)
- Has a reasonable expectation for manufacturer credit (and)
- Meets the following criteria:
- Prescription (or OTC)
- Original container
- < 1 year expired
To get an idea of what constitutes a reasonable expectation for credit, we need to look at examples of pharmaceutical that do not have a reasonable expectation for credit, which include pharmaceuticals that are: Damaged, leaking, samples, investigational drugs, repackaged pharmaceuticals, compounded drugs, floor sweepings, contaminated PPE, and similar.
If you are operating under Subpart P, there are specific management requirements for PCHWP’s that can be found at 40 CFR Part 266.503. These requirements address the issues of: EPA notification, recordkeeping, delivery confirmation receipt, shipping, spill response.
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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