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Document Record Detail

Full Document:
RCRA Online Number:14817
Organization of Recipient:WM Healthcare Solutions, Inc.
Description: Unused dermal patches containing nicotine would be regulated as a listed hazardous waste when disposed. Nicotine in finished dosage forms, such as tablets or capsules, is regulated because it is a commercial chemical product formulation containing nicotine as the sole active ingredient. EPA views transdermal patches as an analogous dosage form. However, after the patch has been applied and removed, it has been used for its intended purpose and therefore would not be listed hazardous waste when discarded. EPA does not view dermal patches to be “manufactured articles”. This letter supersedes an earlier response that was included in a report for the RCRA, Superfund & EPCRA Hotline, RCRA/UST, Superfund and EPCRA Monthly Hotline Report, April 1995 (RO 13741, page 1).
Regulatory Citation(s) : 261.3, 261.11, 261.33, 261.33(d) EXIT disclaimer
Statutory Citation(s): Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Identification of Hazardous Waste; Listing Hazardous Waste; P-wastes; Medical Waste; Hazardous Waste
Approximate Number of Hardcopy Pages:3
EPA Publication Number:NA
RPPC Number (if applicable): NA
Official OSW Policy:


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