February 12, 2020

EPA Allows “PHRM” Code in Manifest Item 13

EPA’s hazardous waste pharmaceutical rule, promulgated in February 2019, established a new Subpart P in Part 266 for healthcare facilities and reverse distributors. [84 FR 5816] We cover this new rule in an extensive white paper available on our website. One provision of this rule requires healthcare facilities to use a manifest when shipping non-creditable hazardous waste pharmaceuticals to a RCRA-permitted TSD facility. However, in lieu of entering hazardous waste codes on the manifest, the healthcare facility must include the word “PHARMS” in Item 13. [§266.508(a)(2)(ii)]

RO 14919 addresses an issue arising from entering the six-character “PHARMS” code on manifests. Since most generators are still using paper manifests, “PHARMS” does not easily fit in Item 13, which was designed for four-character hazardous waste codes. Also, while EPA’s e-manifest system can easily accommodate the “PHARMS” code, state and TSD facility databases are often not designed to accommodate six characters in Item 13, which makes it difficult for them to exchange data with the e-manifest system. As a remedy, EPA requests regions and authorized states that have adopted the pharmaceutical rule to encourage healthcare facilities to use the shortened four-character “PHRM” code on both paper and e-manifests. The agency will consider the use of either code to satisfy the requirements of §266.508(a)(2)(ii).

In a related item discussed in the same guidance, EPA clarifies that healthcare facilities may include all applicable hazardous waste codes on a manifest, as long as the “PHRM/PHARMS” code is also included. Including the applicable RCRA hazardous waste codes may already be required if healthcare facilities ship non-creditable hazardous waste pharmaceuticals through states that have not adopted EPA’s pharmaceutical rule. It may also be required if the state has adopted a more-stringent version of the pharmaceutical rule requiring all waste codes to be present on the manifest.


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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.