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RCRA-C Compliance - Reverse Distribution/Reverse Logistics

Information for Pharmacies and other Retail Facilities

Pharmacies, hospitals, nursing homes, and other health care facilities are responsible for ensuring that the facility is in compliance with RCRA-C hazardous waste storage and handling requirements. To dispose of waste pharmaceuticals that are controlled substances, these facilities have limited options. They can surrender these drugs to a law enforcement officer, or they can send those to another U.S. Drug Enforcement Agency (DEA) registrant. Unfortunately, there are very few disposal facilities that are DEA registrants. To fill this void, and to manage several other complex issues relative to pharmaceuticals, "reverse distribution" companies began operating.

A Reverse Distributor is ...

A "Reverse Distributor" is a company which receives pharmaceuticals from a wholesale or retail seller or a healthcare facility for the purpose of returning unwanted, unusable, or outdated pharmaceuticals to the manufacturer or to another entity that can legitimately reuse the medicine. If the pharmaceutical cannot be reused, the Reverse Distributor arranges for proper disposal. Reverse distribution of pharmaceuticals is well-established and regulated by DEA and the New York State Department of Health, Bureau of Narcotics Enforcement (BNE).

Qualifying for Reverse Distribution

The determination of whether a pharmacy's unwanted pharmaceuticals are solid waste, and whether they are also hazardous waste, may be made either by the pharmacy or by a reverse distributor. If the latter, upon receipt by the reverse distributor, the pharmaceuticals will be inventoried and processed and those items that are determined to be wastes must be managed in accordance with the applicable waste regulations. Details on that process and limitations are detailed in the document linked below.

Reverse Logistics

When the concept is applied to non-pharmaceuticals, it is called, "reverse logistics." Reverse logistics, which can be applied to products as diverse as batteries and household cleansers, is not as well-defined or regulated as reverse distribution of pharmaceuticals, and it should not be assumed that whatever is allowed for pharmaceuticals is also allowed for other products.

Additional Information

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