Transcript Hazardous waste - National Pharmacy Purchasing Association

HAZARDOUS WASTE
THE PHARMACY PURCHASING
PROFESSIONAL’S ROLE
Kathy Pflaum, Inventory Control
Coordinator, Pharmacy
Speaker Disclaimer
 Kathy Pflaum is an employee of St. Francis Hospital in
Topeka, Kansas and has nothing else to disclose
Today’s Objectives – Hazardous
Waste- It Affects You
 Describe the pharmacy purchasing role regarding the
identification and disposal of hazardous waste
 Define the Resources Conservation & Recovery Act of
1976 (RCRA) and the effects on Pharmacy
 Reverse distribution selection processes
Why Do We Care About
Hazardous Waste?
What You Don’t Know May
Cause Harm
 How much hazardous waste is generated by your
facility?
 What happens to the current sharps and red bag
waste?
 Who are the responsible parties in your hospital to
ensure proper handling and disposal of hazardous
pharmaceutical waste?
 Why do you care?*
* Managing Hazardous Pharmaceutical Waste, Pilot Project of North Memorial Medical Center, Robbinsdale, MN Pilot Project
Presentation
Pharmacy Purchasing
Professional – What Can You
Do?
Effecting the Purchase of
Pharmacy Items
 Be observant and document the observations
 Always ask questions
 Probe the entire pharmacy and everywhere
pharmaceuticals are used or stored
 Understand the equation between what is purchased
and how the product is used
 Have a plan for an unidentified delivery
How Can You Effect The
Purchasing?
 Develop and enforce a policy that states that no
medications are accepted into the Pharmacy with
less than 1 year dating
– Medications are purchased with the least amount of
packaging
– Select medications without preservatives whenever
possible*
*These opportunities and further discussion can be found at www.h2e-online.org.
How Can You Effect the
Purchasing?
 Minimize waste wherever possible
– Look for opportunities to change the size or style
bought
– Controlled substances are especially difficult to
waste*
 Inventory controls can be tightened on many
medications thus reducing waste
*These opportunities and further discussion can be found at www.h2e-online.org.
Selection of the Reverse
Distribution Vendor
Pharmaceutical Reverse
Distribution Who Selects This Vendor at
Your Facility?
 Proper permits are required of Reverse Distribution
and you have the right to ask for copies of these
and other permits that may be required by the state:
• DEA Registration
• Local Solid Waste Permit
• State Board of Pharmacy • Local Medical Waste Permit
• EPA Waste ID
Pharmaceutical Reverse
Distribution Who Selects This Vendor at
Your Facility?
 For all hazardous waste disposal,
the reverse distributor should
provide the site information to
which it will be delivered.
ALL HAZARDOUS WASTE IS
“CRADLE TO GRAVE”
The facility owns the waste even in the
landfill.
 All applicable fines for improper waste
disposal belongs to the facility.
What to Know When
Choosing a Reverse
Distribution Company
 Does the reverse distributor have all the proper permits?
 Where does the hazardous waste go from the reverse
distributor?
 What are the charges for disposal of hazardous and nonhazardous waste per pound?
 Is there a processing fee?
 Who pays the freight from the facility to the reverse
distributor facility?
 Off site/On site processing fee?
What is a Hazardous
Waste?
 The EPA* defines a hazardous waste as:
…a waste with properties that make it dangerous or
potentially harmful to human health or the environment.
The universe of hazardous wastes is large and diverse.
Hazardous wastes can be liquids, solids, contained
gases, or sludges. They can be the by-products of
manufacturing processes or simply discarded
commercial products, like cleaning fluids or pesticides.
*EPA web site www.epa.gov/epaoswer/osw/hazwaste.htm
RCRA Law is Administered
by EPA
 Resources Conservation and Recovery Act of 1976*
– Protect human health and the environment from the
potential hazards of waste disposal
– Conserve energy and natural resources
– Ensure that wastes are managed in an environmentally
sound manner
*EPA web site www.epa.gov/epaoswer/osw/hazwaste.htm
Categories of Hazardous
Waste
 Hazardous waste is regulated under the Resource
Conservation and Recovery Act (RCRA) Subtitle C
 Waste is categorized as hazardous if it appears on a
hazardous waste list*
– F-list
– D-list
– K-list
– P-list
– U-list
*EPA web site www.epa.gov/epaoswer/osw/hazwaste.htm
“D” LIST and “U” List
Examples
 “D” listed Pharmaceuticals*
– Barium D005
– Lindane
D013
 “U” listed Pharmaceuticals*
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Acetone U002
Cyclophosphamide U058
Lindane U129
Phenol U188
*EPA web site www.epa.gov/epaoswer/osw/hazwaste.htm
“P” Listed Waste
Effects Pharmacy
 Listed below are a few examples of “P” listed
Pharmaceuticals:
– Epinephrine*
P042
– Nicotine
P075
– Nitroglycerin (weak)** P081
– Physostigmine
P204
– Warfarin (greater than 0.3%)
P001
*Epinephrine salts have been federally excluded
effective October 16, 2007. States may or may not
have adopted this federal stance.
** Nitroglycerin has been excluded from the federal
listing. States may or may not have adopted this
federal stance.
EPA web site www.epa.gov/epaoswer/osw/hazwaste.htm
Other Categories of
Hazardous Waste
 Not all hazardous waste is on a “list”
 Can be considered a hazardous waste if it exhibits at
least one of four characteristics*
– Ignitability
– Corrosivity
– Reactivity
– Toxicity
*EPA web site www.epa.gov/epaoswer/osw/hazwaste.htm
Characteristics of
Ignitability or Corrosivity
 Ignitable* - Aqueous solution containing 24% alcohol or more
by volume & flash point <140° F
– Dehydrated Alcohol <98% Ethyl Alcohol
– Rubbing alcohol
– Paclitaxel in Aqueous solution
 Corrosive* - Aqueous solution having a pH ≤ 2
– Primarily compounding chemicals
– Glacial Acetic Acid
– Sodium Hydroxide
*EPA web site www.epa.gov/epaoswer/osw/hazwaste.htm
Characteristics of
Reactivity or Toxicity
 Reactivity* - meets eight separate criteria
identifying certain explosive and water reactive
wastes
– Nitroglycerin formulations are excluded federally from
the P081 listing as non-reactive as of 8/14/2001 in
FR:5/16/2001**
 Toxicity* - examples include but are not limited to:
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–
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Arsenic
Lindane
Barium
Mercury (thimerosal)
*EPA web site www.epa.gov/epaoswer/osw/hazwaste.htm
• Cadmium
• Chloroform
• Silver
• Chromium
**FR, volume 6 #95 (May 16, 2001)
Don’t Just Consider the
Chemical!
 Hazardous waste (the initial chemical)
combined with:
– Personal Protective Equipment,
packaging and spill materials
– Regulated Medical Waste
– Sharps
– Controlled Substances
 All items MUST be part of the
hazardous waste stream
What Areas Generate
Hazardous Waste?
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Emergency Room
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Home Health
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ICU
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Lab
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Long term care facilities 
Maintenance
Oncology/hematology
Outpatient clinics
Patient care units
Pharmacy
Who Is Watching You?
Enforcement Agencies
 The Joint Commission (TJC)
– Standards in the Environment of Care section 3.10
 U. S. Environmental Protection Agency
 State Department of Health & Environment
The Joint Commission and
Hazardous Waste
 Future ramifications with TJC if an executed plan not in
process
 Surveys now include such questions as:
– How do you separate your waste?
– What is your plan to comply 100% with RCRA?
– Do you waste medications down the drain?
– How does hazardous waste leave the facility?
– Where does the hazardous waste go after leaving the
facility?
– Can you product the logs of hazardous waste that
have been transported out of your facility?
Additional Governing
Regulations
 Clean Air Act
 Clean Water Act
 Emergency Planning and Community Right To Know
Act (EPCRA)
 Toxic Substance Control Act
 Safe Drinking Water Act
EPA - Regions
 The mission of the Environmental Protection Agency is
to protect human health and the environment.
• http://www.epa.gov/
• Click on your region
number for contact
information
Health Care RCRA
Violations from Region #2
Breakout of RCRA Violations from Hospital Disclosures
UST 3%
Container
Management 30%
ID of HW 26%
General Facility
Standards 10%
Accumulation Time
1%
Generator
Requirements 5%
Manifest 5%
Universal Waste
20%
Janet Bowen, EPA Region I 12/7/2006 presentation of Top Ten Compliance Pitfalls Based on
Region II Audit Disclosure Data to SBEAP
Has Green Become A Color At Your
Hospital?
This is Where the Rubber
Hits the Road!
Be Part of the Solution
 Three ways to sort pharmaceutical
waste
– Provide appropriate disposal containers through
out the facility
– Centrally processed sorting of hazardous waste
and medication
– Treat all pharmaceuticals as hazardous waste
Medical Waste vs.
Hazardous Waste
 Red containers are SHARPS containers – Not
hazardous waste receptacles
 Medical waste is defined as waste materials that are
generated at health care facilities (hospitals, clinics,
etc…)
– 4 categories – infectious, hazardous, radioactive,
other*
*EPA web site www.epa.gov/epaoswer/osw/hazwaste.htm
Container Regulations
That Apply
 Most states require clear verbiage stating
Hazardous Waste
 There should be an accumulation start date
 Record log
Who is Disposing Of Your
Hazardous Waste?
 Has the contracted company provided
– Proper licensing to haul hazardous waste? (vs.
medical waste)
– “Bill of lading” documents to haul the waste?
– Identification and proper documentation of disposal
site
Establish a Hospital Wide
Hazardous Waste
Committee
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C-Suite Administrator
Clinics
Surgery
Materials Management
Infection Control
Director of Safety
Environmental Services
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Risk Management
Pharmacy
Nursing
Lab
Radiology
Education/Training Director
Potential Impact of
Compliance
 Financial Impact
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Training and development of staff
Increased waste costs
Additional styles of containers
Additional staff to handle the waste
Outside consultants to achieve compliance
Potential Impact for NonCompliance
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Fines up to $32,500 per day per violation
Legal costs
EPA scrutiny
The Joint Commission - Requirement for Improvement
(RFI)
Pharmacy Purchasing
Professional’s Challenge
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Get involved
Be proactive
Become an expert in hazardous waste
Be the “GO TO” person in the health care facility
Show your leadership skills
Resources Used in this
Presentation
 http://h2e-online.org
 http://www.epa.gov
 Top Ten Environmental Compliance Pitfalls - presented
by Janet Bowen, EPA Region 1 12/7/2006 to SBEAP.
 NIOSH – National Institute for Occupational Safety &
Health
 PharmEcology Associates, LLC - www.pharmecology.com
 Managing Hazardous Pharmaceutical Waste, Pilot Project
at North Memorial Medical Center, Robbinsdale, MN
Presentation
 Covidien (Kendall SharpSafety Division)
 “Managing Pharmaceutical Waste – What Pharmacists
Should Know”, Charlotte A. Smith, RPh, MS, Journal of
the Pharmacy Society of Wisconsin, Nov./Dec. 2002, p. 17.
Questions?