EpiPen Disposal: To Red Bag or Not to Red Bag

A Lifesaving Drug

Epinephrine pens, or EpiPens, can be lifesaving tools. The epinephrine (also called adrenaline) is a cardiac stimulant and is used for severe allergic reactions of all types, including food, drug, insect bites, and stings.

Prescribed to those for whom the risk of anaphylactic shock due to allergic reaction is very high, it comes in the form of an auto-injector or “pen”. This pen contains a hidden syringe which releases the medication instantaneously into the patient’s outer thigh or muscle when the pen is depressed.

Although mostly used for preventing anaphylaxis—a serious allergic reaction that could result in death—the quick-acting drug also has a relaxing effect on bronchial smooth muscles. But if used in the wrong instance, or if injected directly into a vein, the epinephrine itself can be fatal.

These pens are kept in schools, by the military, and in pharmacies across the nation. But it may surprise some to find out that the active ingredient in these pens can be considered a hazardous waste. So safely disposing of EpiPens, whether used, unused or expired, is truly an important matter.

A Hazardous Waste

Based on the Environmental Protection Agency’s (EPA) P-list of acute hazardous wastes, epinephrine is regulated under waste code P042. This covers such generic and trade names as,

• Adrenalin
• EpiPen
• Eppy/N
• Epifrin
• Epinal
• Anaphylaxis kit
• Epinephrine (inhalants, injectables, kits)
• Racepinephrine
• Racord
• Primatene aerosol inhaler

On October 15th, 2007, the EPA published a regulatory interpretation memo regarding the listing of epinephrine and stated the P-listing of the drug was not to include its pharmaceutical salts. Now, all solutions containing epinephrine salts are exempt from hazardous wastes status under federal law. This means that expired, damaged or used EpiPens that contain only epinephrine residue no longer have to be treated as acute hazardous wastes.

It is also relevant to note that some states, including Washington, differ from the EPA’s stance on this particular memo, and do require that containers which have once held epinephrine (spent pens or used syringes) to still be considered dangerous wastes by their own ecological or environmental departments.

It is also wise to understand that any person or company that generates over 2.2 pounds of acute hazardous waste becomes a large quantity generator (LQG) of hazardous waste, and must then be subject to the Resource Recovery and Conservation Act’s (RCRA) laws on record-keeping.

Safe EpiPen Disposal

Used EpiPen Disposal

Empty EpiPens that have been dispensed in the care of a patient may be disposed of as regular medical waste, that is, placed in a Sharps container or a medical red bag.

Unused EpiPen Disposal

Unused pens that contain only epinephrine salt as the active ingredient may also be disposed of as medical waste.

You can usually tell if an EpiPen is a P-list waste (and if it must be disposed of as medical of acute hazardous waste) or not by looking at the manufacturer’s label: if epinephrine hydrochloride, sodium chloride, or sodium metabisulfite are listed, then it is usually not a P-list waste.

But if the EpiPen contains other than epinephrine salts, it must either be sent back to the manufacturer using a reverse distribution program if possible, or be managed as hazardous waste. The latter option would mean disposing of unused or damaged EpiPens via a hazardous waste disposal company or sending them off to a treatment facility using a licensed hazardous waste transporter.