Transcript Hazardous Waste

The Life and Times of Managing
Hazardous Pharmaceutical
Waste
Pamela Hale CPhT, BBA
Mercy Health Partners
Southwest Ohio
Overview
Managing pharmaceutical waste is not new –
neither are the hazardous waste rules.
Focus has typically been on management of
chemotherapy drugs
More recent focus on other types of hazardous
pharmaceutical waste
Regulatory agencies paying more attention to
hospitals and management of hazardous waste,
including pharmaceutical waste
Background
Why is Mercy concerned about Hazardous
Waste Pharmaceuticals?
– Hospitals inspected by Ohio EPA’s Division of
Hazardous Waste; Notices of Violation for failure to
properly evaluate and manage hazardous wastes;
Enforcement Action taken by Ohio EPA – mandated
development of a regional Hazardous Waste
Management Plan
– Hazardous Waste Management Plan - the Plan is
designed to ensure proper management of all
hazardous waste generated at the five Mercy
hospitals.
Responsibilities
Administration - ensure the Plan is fully
implemented at all hospitals
Site Safety Officers –oversee
implementation of the Plan at their hospital
Department Managers - implement the
Plan as it applies to their department
Employees – implement the Plan as
applicable to their specific job duties.
What is a “waste”?
If you are unable to use a chemical for its
intended purpose and you plan to throw it
away, it is a waste.
What is a hazardous waste?
A waste is considered hazardous if:
• It is not excluded from regulation under federal
or state hazardous waste rules and meets one of
the following criteria:
• It is listed in applicable federal or state hazardous
waste rules;
• It exhibits a characteristic of hazardous waste; or
• It is a mixture of a waste and a hazardous waste.
Pharmaceutical Waste
Pharmaceutical Waste – How is it generated in
hospitals?
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IV Preparation
General Compounding
Spills/Breakage
Partially Used Vials
Partially Used Syringes/IVs
Discontinued, Unused Preparations
Unused Repacks (Unit Dose)
Patient Personal Medications
Outdated Pharmaceuticals
Characteristics of Hazardous
Waste
Does the waste exhibit any of the four
characteristics of a hazardous waste?
o Ignitability – easily combustible or ignitable. e.g. – some
nitroglycerin vials, erythromycin gel 2%, flexible collodian.
o Corrosivity – pH < 2 or > 12.5
e.g., acetic acid otic, robinul
o Reactivity – unstable or causes violent chemical or physical
reaction
e.g., silver nitrate applicators; cyanide antidote kit
o Toxicity – contains specific constituents above specific limits
e.g., barium sulfate; m-cresol (insulins); vaccines containing
mercury; silver- containing creams or ointments
Listed Pharmaceutical Waste
P-listed pharmaceutical waste is regulated as
UNUSED discarded commercial chemical
products. P-listed waste is “acute” hazardous
waste.
Examples include:
Arsenic trioxide
Nicotine
Physostigmine Salicylate
Warfarin >0.3%
P012
P075
P188
P001
Listed Pharmaceutical Waste
U-listed pharmaceutical waste is regulated as UNUSED discarded commercial chemical products.
Acetic Acid
Barium Sulfate
Chloral Hydrate (CIV) U034
Collodion
Cyclophosphamide U058
Dermoplast
Dimethyl sulfoxide
Eythl alcohol
Ferric Subsulfate
Influenza
Leukeran
Measles Vaccine (including MMR)
Mitomycin C
U010
Neomycin/Polymixin/Gramicdin Opth
Ocufen
Phenol
Selenium Sulfide U205
Silver Sulfadiazine
Talc
Warfarin <0.3%
U248
Anesthesia Gases (Forane, Suprane,
Ultane)
Benzoin
Chlorambucil
U035
Cortisporin Opth and Otic
Cyanide
Diethylstibestrol U089
Epinephrine (only Epi-pens)
Ethyl Chloride
Glycopyrrolate
Insulins
Lindane U129
Melphalan U150
Mutamycin
Nicotine
Paclitaxel
Physostigmine
Silver Nitrate
Tetanus Toxoid (including DPT, Adacel)
What is NOT a hazardous waste?
Examples:
IV solutions such as normal saline, dextrose,
Lactated Ringers solution, electrolytes – these
can be placed into sewer and the bag and tubing
placed in regular trash.
Caps from vials
Outside baggies
Drugs not labeled with “black bucket waste”
stickers
Chemotherapy waste
Trace amounts of chemotherapy waste are
managed in yellow buckets (“TRACE”
means less than the amount that can be
pulled into a syringe or the residual that
remains in a completely infused IV bag).
Bulk amounts of chemotherapy waste
(greater than trace amounts) are managed
as hazardous waste
Syringes
According to EPA, a syringe is a delivery device,
not a container.
Any residue remaining in a syringe in which the
proper dose has been administered to a patient
is considered to have been used for its intended
purpose and is not a hazardous waste.
Unused syringes (in which a listed drug or drug
exhibiting a characteristic of hazardous waste
has not been fully administered to the patient)
shall be managed as hazardous waste.
Empty rule:
Applies to containers such as IV bags and
tubing, bottles, ampules, etc.
“EMPTY” means all the contents have been
removed by normal means (fully administering
the contents of an IV bag, pulling back all
contents of a vial into a syringe). This is same
as “trace” – less than the amount that can be
pulled into a syringe or the residual that remains
in a completely infused IV bag and tubing.
Regular Trash
EMPTY IV bags and tubing, bottles or
other container. “EMPTY” means all the
content have been removed by normal
means (fully administering the contents of
an IV bag, pulling back all contents of a
vial into a syringe).
Disposing of Pharmaceutical waste
Yellow Bucket
Trace chemotherapy waste (includes IV
bags, tubing, syringes, gloves, supplies
used to administer chemotherapy drugs).
“TRACE” means less than the amount that
can be pulled into a syringe or the residual
that remains in a completely infused IV
bag
Disposing of Pharmaceutical waste
Sharps Container
 Empty syringes of medications. “EMPTY”
means the dose has been fully
administered to the patient.
Disposing of Pharmaceutical waste
Black Bucket (Hazardous Waste)
PHYSOSTAGMINE SALICYLATE AND COUMADIN IV
VIALS - EMPTY OR FULL.
All partially filled vials, IV bags, bottles or other
containers.
Partially filled syringes
Bulk chemotherapy – includes incomplete chemotherapy
infusions, syringes containing unused chemotherapy
drug, and all items used in cleanup of chemotherapy
drug spills.
PPE and other items contaminated from cleanup of spills
involving hazardous waste drugs.
Disposing of Pharmaceutical waste
White Bucket (Hazardous Waste)
All Black Bucket waste that is also
considered infectious waste this includes
partially filled vials, IV bags, bottles or
other containers
Disposing of Pharmaceutical waste
Specific Wastes not mentioned:
– Nicotine – USED nicotine gum and patches
are NOT hazardous waste. Place used
nicotine patches, gum and wrappers in
regular trash.
Specific Wastes not mentioned
Pharmacy will provide Nursing personnel
with information (label) to assist with
proper designation for drugs that are
dispensed to the nursing units.
Black buckets will be available in med
rooms on patient care units
Environmental Services will pick up
buckets when full for transportation to
hazardous waste holding area.
Pharmaceutical Waste
For questions regarding what to discard where contact Pharmacy
For replacement of buckets please contact Housekeeping
All Hazardous
Pharmaceutical Waste
Will have the following label:
BLACK BUCKET WASTE
Black Bucket Waste includes:
•Bulk amounts of chemo
•All drugs with the “Black Bucket
Waste” label
•Any bag, bottle or
container that is labeled as
“BLACK BUCKET WASTE”
•Contaminated items from cleanup
of spills involving hazardous
waste drugs
Partially used syringes go in
White Bucket
Sharps Container:
•All used empty syringes
Sewer System:
•Narcotics (Controlled Substances)
Dispose via the sewer system
with authorized witness.
• IV solutions such as NS, LR,
e
Electrolytes
Regular Trash:
•Non labeled IV tubing and bags
(after removing pt. label)
•USED nicotine patches & gum
White bucket
Yellow Bucket:
•Trace Chemo
Unused/Partially used Syringes with Black
Bucket label
Questions