You have to deal with pharmaceutical waste management if you run either a hospital, an emergency care clinic or a pharmacy. This could include expired pharmaceuticals, bags and vials containing traces of a toxic drug, or pills and liquids that spilled or were spit out by a patient. Surely, there exist many other types of waste produced by a pharmacy, such as product packaging, personal protective equipment, etc. But in this article we’ll use pharmaceutical waste to imply mainly pills, vaccines, ointments and related medications used for treating patients or medical research.
It is very important to collect and dispose pharmaceutical waste in an appropriate manner, because it poses a big risk to the environment and people. If hazardous or bio-active substances enter our ground water or water treatment plants, they may lead to adverse effects in humans, animals and plants on a molecular level. The environment is already polluted with the pharmaceuticals we use to medicate ourselves, our pets and livestock. As a medical facility, it’s your duty to ensure proper collection and disposal of pharmaceutical waste, whether it’s a single vial or an entire case.
Classifying Pharmaceutical Waste
Many different waste items produced during day-to-day operations of a pharmacy or a healthcare facility are included in pharmaceutical waste. These items may belong to the following medical waste categories based on their toxicity and disposal requirements:
- RCRA hazardous waste, specifically P-listed and U-listed substances (chemical products that pose risk to the environment and human health).
- Substances that are not specifically listed as RCRA hazardous waste, but that possess similar characteristics and should be treated as hazardous.
- Infectious waste includes things like live vaccines and blood products.
- Controlled substances that fall under the DEA regulations.
Separating Hazardous and Non-hazardous Waste
The separation of RCRA hazardous waste from non-hazardous waste is considered one of the biggest challenges of managing pharmaceutical waste . This is very important to ensure proper collection and disposal. As it was already said, RCRA hazardous substances are separated into several lists that you can check with.
Thus, you can’t rely on the new substances as they get developed faster than these lists are updated,. If a substance is not on one of the RCRA lists, find the following qualities that RCRA has selected to help identify “characteristic hazardous waste.”
- Ignitability—often a solution containing 24% alcohol or more and has a flash point less than 140 degrees F.
- Corrosivity—has a pH of 2 or lower or 2.5 or higher.
- Reactivity—unstable substances that react with basic elements, such as water, and produce harmful byproducts.
- Toxicity—mostly heavy metals that may be above maximum concentration.
Feel free to click on the links and print out the full definitions provided by the EPA. If one or more of these characteristics are present in a pharmaceutical, treat it as hazardous.
Disposal of RCRA Hazardous Waste
RCRA hazardous waste shouldn’t be collected in red bags as is not the same as infectious or bio-hazardous waste, that’s why it is specifically collected in large drums or smaller black bins with secure lids. it’s important to choose the right container and place a label identifying whether the waste is flammable, toxic or otherwise dangerous due to the fact that hazardous waste can be reactive and corrosive, Some unopened or partially used pharmaceuticals may be eligible for shipping back to the manufacturer.
Never dispose of liquid RCRA hazardous waste by pouring it down the drain. Most water treatment facilities are not provided with such equipment which may help to remove these kind of contaminants from water. RCRA hazardous waste needs to be collected by your Los Angeles medical waste disposal company and transported to an RCRA-approved facility for disposal. This type of waste, before being placed in a landfill, was traditionally incinerated, but the EPA has recently proposed new regulations to require 100% incineration.
New EPA Regulations
As we figured out, the EPA has recently offered new management standards for hazardous waste pharmaceuticals. These standards aim to protect waterways and drinking water supplies from contamination with pharm waste, and also protect the population from mismanagement of hazardous waste.
If admitted, these new standards will apply to any healthcare or similar facilities that deal with RCRA hazardous pharmaceutical waste. What this means to you:
- You will have to follow subpart P of 40 CFR part 266 (the new rule), instead of 40 CFR part 262 (the current rule).
- Pharmaceuticals that are not eligible for manufacturer’s credit (non-creditable) can be managed on or off site. When managed off site, they should be accompanied by the hazardous waste manifest.
- Pharmaceuticals that are eligible for manufacturer’s credit (creditable) can be shipped to the manufacturer.
- Disposal of RCRA pharmaceuticals by pouring down the drain or toilet will be prohibited.
- Hazardous pharm waste managed under this rule won’t count toward determining your status as a small-quantity or large-quantity generator.
- Pharmaceuticals that are also controlled substances under DEA may be exempt from this rule.
- There will be new rules for managing trace hazardous waste (residue left in containers).
As always, you can rely on GLYCON LLC, Inc. to keep you up to date on any new regulations.
Educate Your Staff and Patients
Find out and be convinced whether your personel knows how to separate different kinds of pharmaceutical waste and which containers to use. Besides insuring proper disposal this will help prevent unnecessary exposure to potentially harmful substances. And remember to educate your patients about what they should do with their unused or expired medications. You could even carry out a “send back your unused pills” program to offer your patients an easy solution.
Have any other questions about pharmaceutical waste disposal? Feel free to contact Glycon LLC, and we’ll be happy to clear up any confusion, provide proper containers or offer professional advice.