This SOP addresses the proper disposal procedures for pharmaceuticals that break open in the mail and cannot be rewrapped to forward to the intended customer. Section 691.521 of the Post Office Operations Manual (POM) requires drugs that are found in the mail that are undeliverable to the addressee or sender to be destroyed. The POM also authorizes the donation of over-the-counter drugs that are sealed in their original packaging or container to public and charitable organizations, local food banks, shelters, or other nonprofit organizations that will accept them or destroy them.
Turn over illegal drugs to the Postal Inspection Service. The POM does not address certain classes of pharmaceuticals that the U.S. Environmental Protection Agency (EPA) has determined are hazardous waste, nor does it address the proper handling of controlled substances regulated by the Federal Drug Enforcement Agency. This SOP applies to all Postal Service facilities that generate undeliverable pharmaceuticals and provides supplemental guidance on which pharmaceuticals must be disposed of as hazardous wastes.
The Postal Service™ regularly receives over the counter and prescription pharmaceuticals that become undeliverable when the packaging for those medications becomes damaged or broken in transit. When damaged pharmaceutical mailings cannot be rewrapped and sent to the addressee or sender, the Postal Service must destroy such medications.
The proper method of destruction depends on whether the pharmaceutical is a hazardous waste, a non-hazardous waste, and/or a controlled substance as defined by the Drug Enforcement Agency (DEA). If pharmaceuticals that break open in the mail are not marked, and it is not possible to determine whether they are over the counter or prescription, then these items should be turned over to the Inspection Service.
The EPA lists and regulates certain waste pharmaceuticals as hazardous wastes. Pharmaceuticals may also be considered hazardous if they have hazardous characteristics such as ignitability, corrosivity, reactivity, or toxicity. A pharmaceutical that is either listed as hazardous waste or has hazardous characteristics must be disposed of using one of the USPS-authorized hazardous waste contractors. Some common examples of prescription medicines that the EPA lists as hazardous wastes include warfarin > 0.3%, Epinephrine, Physostigmine, and many chemotherapy agents (see link under Key Websites for an expanded list).
All Postal Service facilities that must destroy hazardous pharmaceuticals must retain records of their disposal using the EPA’s uniform hazardous waste manifest system and dispose of those pharmaceuticals using a USPS-approved hazardous waste contractor. Approved contractors can be found in eBuy2 at http://blue.usps.gov/purchase/eBuy2_home.htm. Search catalogs under “Services” and type in the word “pharmaceuticals” to refine your search.
The DEA regulates pharmaceuticals defined as Controlled Substances. Controlled Substances must immediately be turned over to the U.S. Postal Inspection Service for proper handling and disposal as required by the DEA. Access the list of controlled substances at the DEA’s website (see link under Key Websites). Some Controlled Substances could also be considered a hazardous waste. A partial list of pharmaceuticals that are subject to both regulations can be obtained by contacting the Office of Sustainability (see contact information under Key Websites).
Florida and Michigan allow hazardous pharmaceuticals to be managed as universal wastes using less restrictive management, tracking, and reporting standards. Postal Service facilities in Florida and Michigan are directed to comply with these universal waste regulations since they offer a less burdensome approach to pharmaceutical waste management. California and Washington also provide state specific regulations pertaining to pharmaceutical wastes that apply to Postal Service facilities in these states (see links under Key Websites). For example, nitroglycerin is generally exempt from federal hazardous waste regulations if it is no longer reactive; however, nitroglycerine is not exempt from California's hazardous waste regulations.
Over-the-counter pharmaceuticals can be disposed of in the trash after they are properly destroyed according to FDA or EPA guidelines (see links under Key Websites). Responsible officials in the Postal Service should dispose of pharmaceuticals that are neither hazardous nor controlled substances as follows:
n Follow specific disposal instructions on the drug label, where available. Do not flush prescription drugs down the toilet unless the drug label indicates to do so.
n If no instructions are available on the drug label or the packaging, you can throw the drugs in the trash after determining that they are neither hazardous or a controlled substance and have been rendered unusable by the following actions:
n Mix the drugs with an undesirable substance (e.g., coffee grinds, kitty litter, etc.)
n Place the mixture in a sealed plastic bag before trash disposal.
n U.S. Department of Justice, Drug Enforcement Administration list of controlled substances: http://www.deadiversion.usdoj.gov/schedules/index.html#list.
n U.S. Environmental Protection Agency list of hazardous chemicals (the list includes pharmaceutical chemicals): http://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol27/xml/CFR-2012-title40-vol27-sec261-33.xml
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n U.S. Environmental Protection Agency Guidance for Consumer Pharmaceutical Disposal can be used for over the counter medicines: http://water.epa.gov/scitech/swguidance/ppcp/upload/ppcpflyer.pdf.
n U.S. Food and Drug Administration Guidance on Consumer Pharmaceutical Disposal can be used for over the counter medicines: http://www.fda.gov/downloads/Drugs/ResourcesForYou/Consumers/BuyingUsingMedicineSafely/UnderstandingOver-the-CounterMedicines/ucm107163.pdf
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n The website “Practice Greenhealth” offers a list of pharmaceuticals that are considered hazardous wastes in healthcare facilities and serves as a guide for identifying some of the more common hazardous pharmaceuticals found in the undeliverable mail stream: https://practicegreenhealth.org/topics/chemicals/hazardous-waste-characterization.
n Michigan Pharmaceutical Universal Waste regulations: http://www.michigan.gov/documents/deq/deq-ead-tas-univwaste_320878_7.pdf.
n Florida Pharmaceutical Universal Waste regulations: http://www.dep.state.fl.us/waste/pharm/.
n California Pharmaceutical Waste Regulations: http://dtsc.ca.gov/AssessingRisk/PPCP/Pharmaceutical_Regulatory.cfm.
n Washington Pharmaceutical Waste Regulations: http://www.ecy.wa.gov/programs/hwtr/pharmaceuticals/pages/policy.html
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n For assistance on the proper disposal of over the counter and prescription pharmaceuticals at Postal Service facilities, contact: Sustainability@usps.gov.
n To find approved USPS contractors that provide disposal services for hazardous waste pharmaceuticals, go to eBuy2 at http://blue.usps.gov/purchase/eBuy2_home.htm.
— Corporate Sustainability Initiatives,
Office of Sustainability, 2-20-14
