Today U.S. EPA finalized new hazardous waste regulations in its final Management Standards for Hazardous Waste Pharmaceuticals rule. In brief, the rule creates a new Subpart P to 40 Code of Federal Regulations Part 266, which is specific to hazardous waste pharmaceuticals. The rule applies to all “healthcare facilities” (such as hospitals and retail pharmacies) and “reverse distributors.” The rule requires that all healthcare facilities and reverse distributors manage hazardous waste pharmaceuticals in accordance with the new subpart P regulations. We are carefully reviewing the final rule and implications to clients, as well as implications to state hazardous waste requirements.
The final rule should be published in the Federal Register in the coming weeks, and the final rule will become effective at the federal level six months after publication in the Federal Register.
Join Troutman Sanders and Georgia State Law in Atlanta on February 6, 2019 for a symposium regarding consumer products in the environment, which will include a discussion with U.S. EPA on the new rule. You may view additional detail and register using this link.