Quality Rx Returns

A Better Approach to Return Goods Processing

Contact Us

2936 Middlebrook Pike

Knoxville, TN 37921

727.499.2211 Phone

877.394.5810 Toll Free

865.951.2497 Fax

Hazardous Waste

Hazardous WasteThe EPA requires that any facility accepting RCRA Hazardous Wastes be licensed as a TSDF (Treatment Storage and Disposal Facility). No reverse distributors possess this license. Therefore, if your facility is sending RCRA Hazardous Wastes back to your reverse distributor, you are in violation.

Not all pharmaceutical items that currently end up in the reverse supply chain should be considered Viable Returnable Product. Many products should instead be categorized as Waste Pharmaceutical Product. A determination must be made before any products leave your facility as to whether the item is product or waste. If an item is determined to possess waste characteristics, it must be evaluated for RCRA status prior to shipping. If an item can be categorized as RCRA hazardous, it cannot be shipped to any reverse distributor, since no reverse distributor is licensed as a TSDF.

Waste items include: Compounding chemicals and resulting compounded pharmaceuticals

  • Samples
  • Repackaged products
  • Patient medications
  • Free items
  • Partial creams, vials, or ointments
  • Pharmaceuticals sold on a non-returnable basis
  • Broken, spilled or damaged pharmaceuticals
  • Any drugs out of the manufacturer’s original container

It is common industry knowledge that no credit will be issued for the above waste items. There is no inherent value (e.g., return credit) possible.

Quality Rx Returns provides you with a ‘non-returnable product’ report. This report details which products returned from your facility were destroyed as hazardous products. Some regulators now expect you to examine your previous ‘non-returnable product’ reports to determine which pharmaceutical products sent back are commonly disposed of as hazardous waste. If there is evidence of a particular pharmaceutical product that is routinely destroyed as hazardous waste, then those items should not be sent back to the reverse distributor.

In order to protect yourself from violating EPA regulations, I recommend you immediately establish the following minimum service requirements for your company.

  1. Sort through Waste Pharmaceutical Product items and identify all that are RCRA hazardous waste.
  2. Review your ‘non-returnable product’ report(s) to ensure that items being disposed of on your behalf are being identified as RCRA hazardous or non-hazardous.

Few returns companies are willing to address these problems. Even fewer will be willing to adhere to the standards above. But Quality RX Returns will. Contact us today for a REAL solution to your drug returns.

Quality Rx Returns

2936 Middlebrook Pike

Knoxville, TN 37921

Email: admin@qrxreturns.com

727.499.2211 Phone

877.394.5810 Toll Free

865.951.2497 Fax

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