WHITE PAPER. Pharmaceutical Waste Management
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1 WHITE PAPER Pharmaceutical Waste Management
2 PHARMACEUTICAL WASTE MANAGEMENT Getting a Handle on Drug Disposal Every day, healthcare organizations dispense a broad spectrum of medications. An essential yet often overlooked aspect of this drug delivery process is what to do with any unused medications. Perhaps a patient only requires a portion of a standard dose, leaving some leftover? Or, maybe the organization does not use all of its stock before the expiration dates? Whatever the reason that drugs remain, organizations must have strong processes in place for safely and adequately disposing of these items so they do not become hazards for staff, patients and the community at large. WHY IS EFFECTIVE DRUG DISPOSAL IMPORTANT? Fundamentally, pharmaceuticals are chemicals that can cause problems if not properly disposed of. One of the biggest risks relates to the environment. If an organization throws unused medications in the regular trash or flushes them down the drain, the chemicals can leach into the surrounding environment, contaminating groundwater, drinking water, plant life and so on. Eventually, this can lead to health problems in the community. Organizations should also be aware that certain drugs are highly regulated by agencies like the Environmental Protection Agency (EPA) and the Department of Transportation (DOT). The EPA closely monitors how organizations collect, label, record and dispose of hazardous drug waste. Some States take this a step further and even regulate non-hazardous drug waste. Finally, the DOT regulates how these wastes are transported. Violations of these regulations can lead to severe penalties, which can have serious financial ramifications. Although healthcare organizations have always had to appropriately manage drug waste, some organizations struggle with this activity more than others. For example, in smaller physician practices, there may not be a lot of emphasis on proper drug disposal because an organization may consider the amount of waste it generates to be negligible, and thus believe that the rules don t apply. Staff in these organizations may unknowingly put the facilities at risk by throwing unused drugs in red medical waste bags. The disposal process for regulated medical waste is not the same as for pharmaceutical waste, and drugs can still leach into the environment even if they are thrown out in the red bags. For this reason and others such as permitting and processing requirements, most medical waste disposal facilities do not accept pharmaceutical wastes mixed with medical wastes for disposal. 2
3 SETTING UP A SOLID PROGRAM Creating and sustaining an effective drug disposal program is essential for organizations of all sizes. In fact, once organizations commit to building their programs, they can make them a reality in a few easy steps: 1 Determine what you have. To begin, an organization should determine what kind of waste they generate and the types of medications used throughout the facility and how those items are disposed when they become a waste. Most drugs can be classified into two categories hazardous and non-hazardous which will dictate the correct disposal method. To determine whether a medication is hazardous, an organization may want to consult the EPA or their State environmental agency or a third-party vendor. It s important when working with vendors that they are fully familiar and up-to-date on all state and federal regulations, as these change often. Also, when completing the assessment, don t forget to check commonly overlooked areas such as crash carts and first aid kits that may house medications that expire. 2 Obtain the appropriate containers. If the assessment reveals there are hazardous drugs in the facility, then the organization must have specifically designed containers earmarked for hazardous drug disposal. The easiest way to acquire these receptacles is to work with a vendor that supplies the correct number and size and then periodically comes on site to remove and dispose of the containers according to federal and state regulations. If an organization does not have hazardous drugs, then it can throw away medications in non-hazardous drug containers, which again could be supplied and disposed of by a third-party vendor. Note that if an organization has both hazardous and non-hazardous drugs on site, it can put the two kinds of waste in hazardous drug containers, as long as there are no incompatible medications ones that cannot be thrown away with other items because of the potential for chemical reactions. For instance, unused Silver Nitrate sticks are considered incompatible because they present a fire hazard when combined with other waste. Organizations would need separate containers to house any incompatible items. Although organizations do not have to combine hazardous and non-hazardous drug waste, it can make the waste removal process more cost effective and simpler to manage if done correctly. 3
4 3 Decide where to place the containers. Once an organization determines what containers are necessary and how many it needs, it should decide where to place them. Receptacles should be located in spaces that are easily accessible by staff but not by patients or the general public. Ideal areas might include nursing stations or medication rooms. It also may be beneficial to include posters nearby that remind staff of what drugs should be placed in which containers. 4 Provide staff training. Whether organizations have hazardous drug disposal containers or non-hazardous ones, they should fully train staff on the disposal process so employees know exactly what drug waste to put where. This training should include information about the importance of proper disposal, as well as the steps involved. One thing to highlight is if the organization has P-listed waste, such as Warfarin and Coumadin which are acutely hazardous, then the unused medication and any packaging must be disposed of in the hazardous drug waste containers. There are also specific requirements for weighing the amount of P-listed waste, and that information should also be covered during training. When developing an education program, organizations may want to seek the assistance of outside resources that can not only provide a comprehensive curriculum but offer different kinds of training, such as online resources or turnkey toolkits. COMPLIANCE REALLY IS THAT EASY Proper drug waste disposal is a critical function for all healthcare organizations, not just for large hospitals or multi-site health systems. The good news is that organizations of all sizes can quickly establish a robust program that can prevent negative environmental impacts, ensure regulatory compliance and support patient and staff safety for years to come. For more information about creating a drug disposal program, go to pharmaceutical-disposal/. 4
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