RCRA Compliance Information for Pharmacies & Retail Facilities
To help pharmacies and other retail facilities comply with the federal Resource Conservation and Recovery Act (RCRA), DEC has reviewed both facilities with successful regulatory compliance programs, and those with significant compliance problems. From those reviews, DEC has observed that successful retailers have done three things:
- Developed and consistently implemented facility-specific Facility Compliance Plans
- Developed and effectively implement facility-specific Facility Training Plans
- Assigned individuals to specific compliance tasks and ensure that they are accountable for achieving and maintaining compliance.
DEC Announces Two New Initiatives to Help Retail Pharmacies Prevent Violations and Protect the Environment
DEC is inviting retail pharmacies across the State to participate in an Environmental Audit Incentive Program (audit program) aimed at improving the handling of hazardous wastes. This audit program has significant benefits for retail pharmacies in that it promotes compliance, defers DEC inspections during the audit program time frame and avoids monetary penalties for any violations discovered. Under the second initiative, DEC is promoting proper disposal of unwanted or unused prescription medications by covering the cost of consumer drug collection boxes and drug disposal for two years.
Retail pharmacies may participate in these initiatives by signing an audit agreement and filing an application with DEC no later than May 1, 2017. After that date, DEC will begin inspecting pharmacies for violations if they have not entered the audit program.
Facility Compliance and Training Plan Outlines
The following Plan Outlines detail steps to simplify RCRA compliance:
Clarifying Information for Management of Hazardous Waste
RCRA regulations can be challenging to understand and implement. DEC is committed to providing clarifying information for retail facilities and other generators of hazardous waste.
Two areas that present particular challenges to retail facilities, as identified through DEC inspections, are:
- Management of Universal Waste - including fluorescent lamps and certain batteries.
- Management of Hazardous Waste Pharmaceuticals - including the use of reverse distribution and identifying which products may be a hazardous waste.
When Must a Waste Be Managed as Hazardous Waste?
DEC staff working with individual stores and with parent companies have repeatedly been asked for assistance in properly determining when a solid waste is a hazardous waste. If you have specific questions on hazardous waste determinations, contact DEC through the Small Quantity Generator (SQG) Information Email .
As DEC staff discover the most common waste determinations questions and problems, we will update this webpage.
RCRA Audit Program Briefings
DEC provided two briefings to interested parties regarding the basic requirements of the RCRA program for pharmacies. The first was held on November 10, 2014 at DEC Headquarters in Albany. The second briefing was presented through an online video conference hosted by the NYS Business Council on December 18, 2014. The presentations are provided below:
- Briefing on RCRA and Pharmacies - November 10, 2014 (PDF) (67 KB)
- Briefing and Panel Discussions on RCRA, Pharmacies, and DEC's Audit Policy - December 18, 2014 (PDF) (1 MB)
More about RCRA Compliance Information for Pharmacies & Retail Facilities:
- Management of Hazardous Waste Pharmaceuticals - Guidance on the management of pharmaceuticals that qualify as hazardous waste.
- RCRA-C Compliance - Facility Compliance Plans - Outline for development and implementation of a facility compliance plan.
- RCRA-C Compliance - Facility Employee Training Plans - Outline for development and implementation of a facility employee training plan.
- RCRA-C Compliance - Universal Waste Management - Checklist for identifying, labeling, storing and transporting universal wastes at pharmacies.
- RCRA-C Compliance - Reverse Distribution/Reverse Logistics - Alternatives for disposal of waste pharmaceuticals and non-pharmaceuticals.
