Can I still manage my State-only pharmaceutical waste under the Conditional Exclusion in WAC 173-303-071(3)(nn) ?
Yes, you can choose to segregate the State-only pharmaceutical wastes and manage these under the Conditional Exclusion. If you do this, you may benefit from lower disposal costs. However, you may have increased internal costs, such as educating your staff on proper segregation, and ensuring compliance. Conditionally excluded pharmaceutical waste must be disposed of at either a permitted municipal solid waste incinerator or an incinerator that meets the following criteria: heat input greater than 250 million btu (British thermal units) per hour or a combustion zone greater than 1500°F. If you choose to mix the State-only pharmaceutical waste with the RCRA hazardous pharmaceutical waste, then you must manage the combined wastes according to the Dangerous Waste Regulations or according to the Policy. If the wastes are managed according to the Policy, Ecology will refrain from enforcing portions of the Dangerous Waste Regulations within its enforcement discretion.
