Hazardous waste generation and management practices at health care facilities and other generators of hazardous pharmaceutical wastes differ from practices of industrial hazardous waste generators in several ways that make the application of RCRA Subtitle C hazardous waste regulations difficult. Pharmaceutical waste is typically generated at a large number of points in relatively small quantities across a facility, such as at nursing stations, pharmacies, and patient, emergency, and operating rooms. Furthermore, generators of hazardous pharmaceutical wastes tend to generate hundreds of different types of pharmaceutical waste while, in contrast, many industrial generators tend to generate only a few predictable waste streams in large quantities at relatively few generation points. Some of the difficulties that generators of hazardous pharmaceutical wastes have expressed concerning the current hazardous waste generator regulations relate to making the waste determination, generator status upgrade due to generation of acutely hazardous waste, hazardous waste listings, and accumulation time limits.
For more information, see http://www.epa.gov/epawaste/hazard/wastetypes/universal/pharm.htm