Waste collection for pharmacies and clinics

Pharmacy back rooms and clinic cupboards hold more than people expect. Out of date medicines are the obvious part, but the chemical items are usually the ones with no route at all. We expect to see:

• dispensary stock that has gone out of date or been withdrawn, kept apart by type
• compounding and extemporaneous dispensing chemicals, some of them very old
• disinfectants, sterilants and descalers from clinical areas
• laboratory or point-of-care reagents and test kits
• solvents and skin preparation chemicals used in private clinics

Controlled drugs are handled as a manual enquiry, and so are compressed gas cylinders and any chemical that looks unstable. That includes liquid nitrogen dewars and cylinders in dermatology or aesthetic clinics, where the normal route is usually back to the gas supplier.

• the medicine or chemical name, strength and quantity, kept as separate lists
• which items are cytotoxic or cytostatic, based on your pharmacist's review
• what your existing NHS or clinical waste contract already collects
• any controlled drugs held for disposal, listed separately and not added to the main list
• opening hours, parking restrictions and the best time for a collection outside patient hours
• a contact who is authorised to sign for your premises

Nothing on a list should identify a patient. Do not include patient details on the collection list. Keep medicine and chemical identification labels intact, and handle patient information under your own information governance arrangements. If you cannot do that safely for a particular item, tell us and we will agree how it is described.

These categories are easily confused. In England, NHS pharmacists must accept and dispose of unwanted drugs presented to them, and commissioners commonly arrange a waste contractor for those returns. Your commissioner or integrated care board can tell you what your local contract covers. GOV.UK gives specific codes for household medicines returned to a community pharmacy: 20 01 31* for cytotoxic and cytostatic medicines, and 20 01 32 for others.

Your own dispensary stock is a different question. Expired or withdrawn stock from a healthcare setting is coded 18 01 08* if cytotoxic or cytostatic, and 18 01 09 for other medicines. A private prescriptions service, a travel clinic or a hospital outpatient pharmacy may be working under different terms again. Find out what your contract says before you assume it covers everything in the bin.

The code changes the paperwork. A 18 01 08* consignment is hazardous waste and moves on a consignment note. A 18 01 09 load is non-hazardous and uses a waste transfer note, which both parties sign and keep for two years. A mixed container turns the question into a problem, so keep them apart from the start.

Most people think of chemotherapy, but the waste definition is wider. HTM 07-01 defines a cytotoxic or cytostatic medicine for waste purposes as any medicinal product with one or more of four hazardous properties: acute toxicity, carcinogenicity, reproductive toxicity or mutagenicity. It notes that some of these medicines are commonly prescribed, and gives chloramphenicol as an example. Mixing them with other medicines is prohibited in England and Wales, except in homes.

The practical test is the medicine's data, not the ward it came from. A purple-lidded bin should be available wherever these medicines are handled, and staff need to know that an ordinary eye drop can belong in it. Your pharmacist will know which products in your formulary need that treatment. If nobody has checked, the list is worth drawing up once and keeping beside the disposal bins.

Controlled drugs have rules of their own, and they are not something we would add to a routine list. In England, GOV.UK says pharmacies and veterinary surgeries must sort and denature waste controlled drugs before disposing of them, and that a T28 exemption is needed to do this. The exemption is free. It requires an authorised person under the Misuse of Drugs Regulations 2001 and limits you to 1 cubic metre at any one time, stored for up to 6 months. It does not allow you to treat drugs that are hazardous waste, or waste produced somewhere else.

The exemption rules are changing. GOV.UK says new waste exemption rules are expected from January 2027, subject to parliamentary approval, so check the current wording before you renew. Destruction requirements under the Misuse of Drugs rules, including witnessing, also remain your responsibility. When a pharmacy has a backlog, it comes to us as a manual enquiry, with the regulatory responsibilities kept clear.

Pharmacies that have traded on one site for decades often have a shelf or cellar nobody has looked at since extemporaneous dispensing faded out. Typical finds include strong chloroform water concentrate, collodion, ether, iodine preparations, old powders in glass jars and poison-cupboard stock from a former owner. Some of these change with age. Collodion is nitrocellulose in a volatile solvent, and it should not be allowed to dry out. Ether can form peroxides, which is a reason to leave an old, opened bottle closed and where it stands.

The same happens when a pharmacy changes hands. A buyer may take on the store along with the premises, and with it the waste. The time to raise it is during the sale, while the previous owner can still say what the bottles are. A chemical store assessment is a sensible way to establish where you stand if the original knowledge has already gone.

Clinics sit in between. A GP surgery, aesthetic clinic, physiotherapy practice or private hospital outpatient unit generally has a clinical waste contract for sharps and contaminated dressings. That contract is not automatically a route for chemicals, and HTM 07-01 says waste chemicals should not go into clinical waste streams. Liquid medicines also should not be discharged to the sewer.

The pre-acceptance audit catches some clinics out. A healthcare site producing under 5 tonnes a year generally needs one every 5 years, or every 2 years for dental and veterinary practices and laboratories, and permitted sites need that audit before they will take the waste. If your clinic has moved or added a service since the last audit, tell your clinical waste contractor.

The duty of care does not reduce because the volume is small. You still need to check that whoever takes your waste is authorised, and a written description has to travel with it. Keeping that evidence in a single folder makes life much easier when ownership or management changes.