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RCRA · Hazardous Waste

P-Listed & U-Listed Drugs Explained

Some everyday medications are federally hazardous waste — and the P-list and U-list are how the EPA defines them. Here’s what P-listed and U-listed drugs are, with the common examples that surprise most facilities.

In this guide

  1. P-listed
  2. U-listed

P-listed drugs (acutely hazardous)

P-listed drugs are acutely hazardous waste — the strictest category. Common examples: warfarin (above certain concentrations), nicotine (P075), epinephrine, and physostigmine. Even the empty container that held a P-listed drug can be regulated.

These must be managed as RCRA-hazardous pharmaceutical waste.

U-listed drugs (toxic)

U-listed drugs are toxic pharmaceuticals and their residues — a broad category including many chemotherapy agents and other toxic drugs. Like P-listed, they can’t be sewered or trashed.

How they're disposed of

P- and U-listed drug waste is segregated, containerized, manifested, and incinerated at a permitted hazardous-waste facility under RCRA Subpart P — with documentation. We identify and route them so they never hit the red bag or the drain.

Get your hazardous drugs identified.

We identify P-, U-, and characteristic drug waste, segregate it, and destroy it compliantly — manifested, with a Certificate of Destruction.

Frequently asked questions

What are P-listed drugs?

P-listed drugs are acutely hazardous pharmaceutical wastes under RCRA — the strictest category. Examples include warfarin, nicotine (P075), epinephrine, and physostigmine.

What are U-listed drugs?

U-listed drugs are toxic pharmaceuticals and their residues, including many chemotherapy agents — also regulated as hazardous waste that can't be sewered or trashed.

Is warfarin or nicotine hazardous waste?

Yes — warfarin (above certain levels) and nicotine (P075) are P-listed acutely hazardous waste and must be managed under RCRA, not thrown in the trash.

How are P- and U-listed drugs disposed of?

Segregated, containerized, manifested, and incinerated at a permitted hazardous-waste facility under RCRA Subpart P, with documentation.