August 30, 2006
REGULATORY COMPLIANCE NOTICE – UPDATE: Epinephrine Waste Management
Dear Health Care Administrator,
This regulatory Compliance Notice is provided as an update and correction to the June 12, 2006
Regulatory Compliance Notice sent to you regarding the regulation of epinephrine wastes. After further
review of the regulations and the underlying chemistry of epinephrine, the Department has determined
that materials contaminated by epinephrine salts are not hazardous waste and/or do not need to be
managed as hazardous waste.
In practice, this means that all aqueous solutions containing epinephrine salts (which should include
essentially all medical applications) and all wastes associated with the use of these solutions, including
vials, ampules, bottles, bags, tubing, and syringes, are not hazardous wastes and not subject to hazardous
waste regulations. These wastes are, however, solid wastes and medical wastes and still need to be
managed in compliance with solid waste requirements.
We regret any hardships our June 12, 2006 letter caused. Prior to that letter, we were unaware of the
widespread use of epinephrine salt solutions in medical applications and were concerned that many in
the medical community were unaware that epinephrine was a chemical that EPA added to the list of
acutely hazardous wastes back in 1980. Our initial research leading up to the June 12 letter indicated
that many states considered the epinephrine wastes to be hazardous wastes. In addition, many medical
waste resource groups, such as H2E (Healthy Hospitals for the Environment), also advised the medical
community to consider all epinephrine wastes to be hazardous. It was against that backdrop, but before
we performed our own research into the issue, that the June 12, 2006 letter was sent to you.
Pure epinephrine (or epinephrine base; CAS 51-43-4; C9H13NO3) appears in the Colorado hazardous
waste regulations as a P042 listed acutely hazardous waste. This form of epin