State Implementation of New EPA Standards for Maintenance of Hazardous Waste Pharmaceuticals: Drug Supply Chain Implications

Read the full story at JD Supra.

Earlier this year, the Environment Protection Agency (“EPA”) adopted a final rule imposing new standards for the management of hazardous waste pharmaceuticals (“HWPs”)[1] that goes into effect on August 21, 2019 (“Final Rule”).[2] This comprehensive overhaul of rules governing the treatment and discarding of HWPs under the Resource Conservation and Recovery Act (“RCRA”) is largely intended to provide regulatory clarity and national consistency. However, many of the Final Rule’s core provisions must first be adopted at the state level within the next two to three years, meaning that inconsistencies could arise based upon each state’s interpretation and adoption of these provisions. This implementation process will therefore be critical to affected pharmaceutical supply chain entities, which will need to proactively engage state lawmakers to ensure efficient management operations.

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