Defining pharmaceutical waste

Pharmaceutical waste is medicines that cannot be returned or reused. It includes medicines that are out-of-date, damaged, no longer required or unsuitable for their intended use. In addition, it includes part-filled and empty medicine containers.

Identifying types of pharmaceutical waste and disposal containers contains further information on specific types of waste.

Legislation and guidance

Healthcare settings must ensure that pharmaceutical waste is disposed of or destroyed in a safe and secure manner. This should be in accordance with legislation, regulations, and organisational policies or procedures.

NHS England

There is both legislation and regulation that underpins how healthcare waste (including pharmaceutical waste, sometimes called ‘medicinal waste’) should be handled, including the use of approved containers. This is summarised in NHS England’s Management and disposal of healthcare waste (HTM 07-01).

Royal Pharmaceutical Society

The Royal Pharmaceutical Society’s Professional guidance on the safe and secure handling of medicines covers all potential activities that are associated with the handling of a medicine, from obtaining the medicine through to use and the disposal of any waste.

Environment Agency

The requirements of the Environment Agency are covered in Managing Controlled Drugs (CD) waste.

Disposal principles

NHS England has produced a clinical waste strategy to deliver sustainable waste management.

Pharmacy services need to consider these principles wherever possible, while keeping the nature of pharmaceutical waste in mind:

• reduce
• reuse
• reprocessed
• renewable
• recyclable

Ultimately, all pharmaceutical waste is for incineration. To reduce our carbon impact, it is important to ensure only pharmaceutical waste is classified as such.

The NHS is committed to reducing its carbon footprint and Delivering a ‘Net Zero’ National Health Service gives more information on the interventions that can be taken on inhalers and anaesthetic gases.

Handling pharmaceutical waste

The following practical considerations should be taken in to account when handling pharmaceutical waste.

Wearing appropriate personal protective equipment (PPE)

Following a local risk assessment, gloves and an apron may be deemed necessary PPE when handling pharmaceutical waste.

Segregating waste

There is a requirement to segregate pharmaceutical waste into hazardous and non-hazardous waste. Where it is unsafe or not possible to do so, it should be consigned as mixed hazardous and non-hazardous waste medicines and the relevant European Waste Catalogue (EWC) codes for each type of waste included on the consignment note.

There is usually no requirement to segregate different types of formulations e.g. tablets from liquids. Some waste contractors will require that medicines in aerosol form must be segregated. If this is not done, the presence of aerosols must be identified on the accompanying waste documentation.

Disposal containers

Pharmaceutical waste must be placed in a leak-proof container, which has been UN-approved for liquids.

The container should be clearly labelled to identify the waste type using a black permanent marker pen before filling.

Do not fill the container beyond the fill-line. Once the container is filled, it should be securely sealed and the appropriate consignment note completed.

Storing pharmaceutical waste

Pharmaceutical waste should be dealt with promptly to avoid accumulation. Ideally it should be disposed of where it is generated.

If pharmaceutical waste is not disposed of immediately, it must be stored securely until it can be further managed. This also applies to containers in use.

Transporting pharmaceutical waste

This applies to waste that is in the disposal container.

Only licensed carriers can transport pharmaceutical waste. Ideally pharmaceutical waste should be collected by the licensed waste contractor from the site where it is generated.

Exemption for home healthcare workers

Healthcare workers are responsible for managing the waste generated from treating an individual in their own home. For example sharps waste as a result of the healthcare worker administering an injection should go in the sharps bin held by the healthcare worker.

Home healthcare workers do not need a licence to transport pharmaceutical waste they have generated in the home environment back to their base or site.

Working with waste contractors

The organisation producing the waste bears the legal responsibility of ensuring that waste documentation is complete and accurate.

There are two different types of documentation required for pharmaceutical waste:

• waste transfer notes for non-hazardous waste
• consignment notes for hazardous waste

Both the consignment note and the waste transfer note require the wastes to be listed, together with the six digit EWC (European Waste Catalogue) code(s).

The organisation producing the waste is legally required to correctly describe the waste produced, including appropriate codes. Waste contractors may supply pre-printed consignment or waste transfer notes.

Record retention

Stock handling, waste and recall records in pharmacy contains further information.

Patient-generated pharmaceutical waste

The following advice supports the management of pharmaceutical waste that has been generated by patients themselves.

Unwanted medicines

Patients, relatives or carers should be encouraged to dispose of unwanted medicines by returning them to a community pharmacy in their original packaging. Community pharmacy contractors are obliged to accept back unwanted medicines from patients.

Sharps waste

Sharps generated from an individual self administering in their own home should be managed by the individual.

Managing sharps contaminated with pharmaceutical waste contains further information.

Illicit substances

Occasionally, pharmacies may receive illicit substances for disposal. Where this is considered pharmaceutical waste, this guidance may be followed in line with local standard operating procedures (SOPs). Appropriate documentation should be kept and organisations might want to use their controlled drugs register. Local policies on when to involve the police should also be followed.

Where this waste is not considered to be pharmaceutical waste, it is suggested that the organisation’s waste manager is contacted. Alternatively, the local council waste department may be able to assist.

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