10 Key Focuses for Proper Pharmaceutical Waste Disposal
January 21, 2019

Clinics, hospitals, pharmacies, and all types of healthcare facilities have a growing concern for how to properly and safely dispose of their hazardous waste materials. There is a worry how to correctly dispose of vials and bags that contain trace quantities of toxic substances, spilled liquids, pills, expired pharmaceuticals, protective gear, and even the material used as packaging for drugs and medicines that can be classified as waste.

There are different risks governed by separate sets of regulations for various forms of pharmaceutical wastes. It is imperative you use the proper type of disposal as there are severe penalties attached to not following guidelines or laws set up to protect the environment and human life. Depending on the circumstances involved, you could be looking at medical waste violation fines from $5,000 to $70,000 for each violation under OSHA guidelines. These are ten key focuses for proper pharmaceutical waste disposal to ensure your facility is following the law.

1. Know Your Hazardous Waste
Pharmaceutical waste does fall under just one category. There are several categories and the chemicals that make up the pharmaceutical dosage forms are very diverse and complex. Pharmaceutical waste management has not always been an area healthcare professionals have focused on, so there are many misconceptions regarding the proper way to dispose of them.
The RCRA (Resource Conservation and Recovery Act) defines a hazardous waste. This form of waste has the possibility of causing significantly incapacitating illness or can possibly increase mortality. It is a waste that is a substantial hazard to human health or the environment when it is not treated, transported, stored, and disposed of properly.

2. Which of Your Pharmaceutical Wastes are Considered Hazardous under RCRA?
Common drugs like cyclophosphamide, lindane, nicotine, and warfarin are considered hazardous under RCRA guidelines. There are four characteristics which are used by the RCRA to define hazardous waste; reactivity, toxicity, corrosivity, and ignitability.

3. Create Designated Containers for Proper Waste Disposal
Having designated containers which are properly labeled for your different pharmaceutical waste will ensure everyone in your workplace knows where to place materials correctly. Different waste, for example, that fall under the RCRA (Resource Conservation and Recovery Act) may need to be segregated from those that are non-RCRA.
You can create alternate containers for controlled substances as well as chemotherapy drugs. Using a color scheme will help those responsible for disposing of waste keep the different materials in their proper containers. Make sure your staff understands the containers should be in authorized areas only and kept closed at all times.

4. Choose an Expert Healthcare Waste Management Consultant
There are a lot of rules and regulations associated with pharmaceutical waste disposal. You want a professional healthcare waste management consultant working with you and your staff who understands the complex system of disposing of properly. You want a company who understands the objectives for creating cost-effective and innovative solutions to meet all your disposal needs.
A healthcare waste management company will minimize your liability and protect the environment. With the right waste management team, you can obtain chemical lab packing services and disposal, hazardous waste incineration, radioactive waste disposal, hazardous waste disposal, and many other green disposal methods.

5. Provide Pharmaceutical Waste Disposal Training for Your Staff
Employees need to be knowledgeable and up-to-date regarding pharmaceutical waste from your facility. It is crucial they fully understand where and how to dispose of all materials they use or work around. They should all know the correct quantity, type, and size of the pharmaceutical waste container to use for all material disposals.
Train your staff during orientation, so they start out on the job knowing the regulations and then provide annual updates or refreshers. Document all training sessions to prove training has been provided to all staff members.

6. Understand what RCRA Empty Means
If a container has held a P-listed hazardous waste, it must be emptied of all its contents and rinsed three times in order to be considered ‘RCRA empty.’ If a container has held a U-listed waste or a characteristic waste, it must be emptied of all its contents through normal means, such as with the use of a syringe and be left with no more than three percent by weight of its contents.
If your containers can meet both of these conditions, then they are not regulated under hazardous waste rules. An exception made by the EPA is for syringes used for U and P-listed waste. These can be disposed of in either the red biohazardous sharp containers or the yellow trace chemotherapy containers depending on which drug was used them.

7. Know the Difference between Bulk Chemotherapy and Trace Waste
According to the EPA, if you have containers holding chemotherapy agents such as, arsenic trioxide which is a P-listed hazardous waste, it is not considered RCRA empty. The container would have to be emptied of its contents and then triple rinsed. This procedure is not always possible for those in healthcare facilities, so it is recommended you discard containers that have held arsenic trioxide as hazardous waste containers regardless of the contents. A syringe is the only exception to this rule as it can be discarded as trace chemotherapy.
Other containers considered as RCRA empty are eight other chemotherapy drugs regulated by the EPA as hazardous waste and are on their U-list. If you have removed all the contents that can be removed through normal use, such as drawing liquid out with a syringe and leave no more than three percent remaining, it can be disposed of as a trace chemotherapy in a yellow container. If you are not able to remove enough of the waste, it then should be disposed of as hazardous waste as a bulk chemotherapy waste.

8. Is Your Facility in Compliance with RCRA if You Have a Chemotherapy Waste Contract
You are not necessarily compliant with RCRA just by having a chemotherapy waste contract. Incineration firms and medical waste haulers specify in their waste acceptance guideline if they only handle paraphernalia. These companies will only dispose of your syringes, IVs, tubing, gloves, gowns, and empty vials. These items would fall under the trace chemotherapy category and have to be incinerated at medical waste incinerators that are regulated. This incineration prevents exposure to your staff while being disposed of through microwaving, autoclaving, or other alternative treatment.
Bulk chemotherapy waste needs to be handled as hazardous chemical waste. There are not EPA regulations in place for these as they regulate only nine chemotherapy drugs at this time. The nine drugs considered as hazardous chemical waste by the EPA include; chlorambucil, arsenic trioxide, diethylstilbestrol, streptozotocin, uracil mustard, cyclophosphamide, daunomycin, mitomycin, and melphalan. The drugs on this list are required to be segregated from yellow chemotherapy, red bags, or red sharps waste containers. These nine are to be placed in Resource Conservation and Recovery Act hazardous waste containers when present in large amounts.
It would be to your facility’s advantage to treat all large amounts of chemotherapy agents as hazardous waste in your disposal methods. Many of the non-regulated chemotherapy agents are as hazardous as the nine listed above, so it is good practice to handle all as hazardous. Chemotherapy spill clean-ups are traditionally put into yellow chemotherapy waste containers as they are overly contaminated and treated as hazardous waste.

9. Know that your Pharmaceutical Waste is being Handled Correctly
Having a hazardous waste management and disposal company you trust and who understands your waste disposal needs is essential. You want a company who specializes in proper identification, management, and segregation of all your pharmaceutical wastes. It is vital that all EPA rules and guidelines are followed correctly in regards to labeling and disposal to ensure you comply with the law.
If you are able to answer ‘yes’ to any of these questions, you should reconsider your policies of hazardous waste disposal:
Are you disposing of any materials from IVs or other compounded fluids down your drains?
Are you placing any syringes, vials, or IVs with trace amounts of chemotherapy remaining in them into the yellow ‘chemo waste’ containers?
Are you placing red sharps with pharmaceutical waste in them inside the red sharps containers located in your patient care units?
Are you combining waste pharmaceuticals such as nicotine or warfarin with other nonhazardous pharmaceutical wastes?
Environmental Marketing Services can assess your risks and set your facility up with solid recommendations to ensure you are at, and remain, in compliance with the complex waste management laws.

10. How You Manage Your Hazardous Pharmaceutical Waste in Relation to the Joint Commission Accreditation Process
Pharmacists generally focus their compliance with the Medication Management Standards set forth by the Joint Commission, and Safety Officers along with environmental service managers focus their disposal methods with the Environment of Care Standards. Everyone needs to work closely together to ensure pharmaceuticals work together in response to the Environment of Care Standard 3.10, as under this standard, pharmaceuticals are hazardous materials.
The Joint Commission Environment of Care Standards describes specific actions you are required to comply with in disposing of your hazardous waste. Under these standards, pharmaceuticals are potentially hazardous materials. These materials also fall under OSHA Hazard Communication Standards and the EPAs Resource Conservation and Recovery Act. These standards make having a reliable disposal company working with you vital to your facility’s safety.

The Environmental Marketing Services are professionals who welcome the opportunity to work with you and your facility. We have more than 90 years of combined experience and understand the importance of meeting your objectives to create innovative solutions with cost-effective standards. We are able to minimize liabilities while protecting the environment in all your disposal and recycling needs.

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