Magazine article Health Facilities Management

Managing Drug Waste: How Small-Quantity Generators Can Achieve Compliance

Magazine article Health Facilities Management

Managing Drug Waste: How Small-Quantity Generators Can Achieve Compliance

Article excerpt

A great concern for health care facilities of all sizes is pharmaceutical waste compliance. It is clear that the problem is multifaceted and takes broad cooperation on the part of many different groups to find a comprehensive solution.

The Clean Water Act of 1972 provided protection for surface water quality in the United States and empowered the Environmental Protection Agency (EPA) with authority to employ tools to restrict pollutants from entering public water supplies. A U.S. Geological Survey in 2002 confirmed that pharmaceutical compounds were detected in 80 percent of the 139 streams sampled in this country. Then the EPA released a 2008 study on unused pharmaceuticals in the health care industry that discussed the management and disposal of unused pharmaceuticals and the presence of pharmaceuticals in the water supply (http://water.epa.gov/ scitech/swguidance/ppcp/upload/2010_1_11_ppcp_hcioutreach.pdf.)

How do the drugs find their way into the water supply? Primary factors cited in the EPA report are direct excretion or improper disposal by patients themselves and improper disposal by health care facilities. All too often, health care facilities improperly flush pharmaceuticals, place them in "red bag" regulated medical waste or just throw them into the trash. All three routes can lead to having drugs enter the water supply.

According to the EPA report, pharmaceutical waste is generated at health care facilities before, during and after patient treatment. Approximately 3 percent of all purchased medications expire before they are ever used. Whether drugs are expired or samples are not used, the EPA's concern remains the same--proper disposal to prevent any drugs from getting into the water supply by direct disposal or as a result of leaching out of landfill waste.

The 1976 Resource Conservation and Recovery Act (RCRA) gave the EPA authority to control hazardous waste from cradle to grave. However, there are not yet specific RCRA regulations directed toward disposal of pharmaceuticals by health care facilities. Such facilities are subject to the same RCRA

requirements as any other industry.

It is estimated that 95 percent of the pharmaceuticals disposed of by small-quantity generators such as physicians' practices, clinics, ambulatory surgical centers and nursing homes fall into the non-RCRA hazardous category. State rules vary, so both non-RCRA and RCRA waste should be segregated and handled separately from regulated medical waste. While such waste disposal services have existed for large facilities such as hospitals, there have been few options for these smaller facilities. Pharmaceutical disposal services are a viable option to prevent improper disposal and for keeping every type of facility in compliance with regulatory requirements.

Best-management practices

Pharmaceutical waste is different from viable pharmaceutical products, which have value when returned to the manufacturer or distributor. Compliant disposal for pharmaceutical waste includes pharmaceutical items that cannot be used for their intended purpose and must be discarded. Small-quantity generators should be trained to identify which medications can be sent back to returns processors or reverse distributors for credit. Items without creditable value should be properly managed as pharmaceutical waste.

A medical office building with independent or individual practitioners, a small nursing home or ambulatory surgical center can properly dispose of pharmaceuticals through simple, best-management practices. State and local regulations, applied by waste stream management companies, help to ensure that segregation and proper disposal of pharmaceutical waste from regulated medical waste is not only compliant, but also environmentally sound.

Waste minimization is the first step to reducing the amount of pharmaceutical waste generated at the source. RCRA hazardous waste generators are encouraged to take measures to reduce amounts generated. …

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