Although RCRA standards have been in place for over 35 years, there has traditionally been little enforcement of these standards in health care facilities. But as enforcement by federal and state inspectors increases, accompanied by growing public interest in environmental issues many hospitals and other health care facilities are now placing greater priority on an appropriate pharmaceutical waste management program.
New Hanover Regional Medical Center (NHRMC) is a two hospital health system in Wilmington, North Carolina, with 883 licensed acute care beds. In addition, NHRMC has 36 inpatient and outpatient surgical suites, a level II trauma emergency department, and seven outpatient clinics, including an outpatient oncology infusion center. In 2009, prior to implementation of a formal waste management program, we estimated our pharmaceutical waste generation to be 50,000 pounds per year. At that time, medications were disposed of via biohazardous waste containers, the regular trash, and the municipal sewer system.
Finding the Right Program
The first step in organizing our waste management was to educate hospital leadership on the meaning and importance of proper disposal, and to provide cost estimates for doing so. In presenting our case, emphasis was placed on regulatory compliance and the impact on the municipal sewer system. After demonstrating the need for a formal, RCRA compliant program, we received immediate support from hospital leadership. In speaking with other health care facilities in North Carolina we learned most used an outside vendor, although several had developed homegrown programs. Without the resources and in-house expertise to develop and manage a homegrown program, we elected to contract with a vendor to help manage our waste.
The characteristic we placed the greatest emphasis on was the ability to manage waste from cradle to grave. This included waste collection at the point of administration, temporary in-house storage, pickup, transportation, and incineration. While we initially selected a cost effective vendor with good customer service, after continued research, we discovered Clean Harbors, a vendor with all of the strengths we wanted. They offered a program with onsite management, visibility to final disposal, shared responsibility for 100% regulatory compliance, all with one of the lowest cost structures. An on-site Clean Harbors staff member was a large part of the overall cost estimate, with the remainder tied to the per pound cost of waste handling using a one bin system, as well as the supplies needed to implement the program. We debated whether to include the on-site personnel, but decided that not having that support would leave us vulnerable to a loss in compliance. Additionally, Clean Harbors owns and operates their own incinerator, which increases overall control of waste through the disposal process.
While some programs require segregation of hazardous pharmaceutical waste from non-hazardous, we decided to manage all pharmaceutical waste as hazardous. After speaking with nursing and pharmacy staff, it was clear that segregating waste based on classification would be overly difficult. Managing all waste as hazardous would simplify the program and decrease the burden on hospital staff. We also believed that an intricate and confusing program would jeopardize compliance with RCRA regulations and lead to workarounds by staff. By combining all pharmaceutical waste in a single bin, we have drastically reduced the likelihood that a medication will be disposed of incorrectly. Additionally, this route has eliminated the need to store multiple types of waste receptacles at each collection point, thus decreasing supply costs and not taxing the valuable floor and storage space in patient care areas.
After selecting Clean Harbors as our vendor, we developed a straightforward training program in collaboration with our Clean Harbors representative using an online module, and assigned this training as mandatory education for all pharmacy and nursing staff. We met with representatives of all departments involved in generating pharmaceutical waste to provide education, while dispensing the bins to centralized locations on each care unit. After our on-site Clean Harbors staff member was oriented to our facility, he was able to work with each unit to further educate staff and oversee the program.
After working with Clean Harbors for over a year, we remain extremely satisfied with their service and our resulting waste management compliance. The simplicity of the program makes it easy for new staff members to master, and the on-site representative ensures any day to day issues are resolved quickly and effectively. Following the program implementation, we were inspected by the North Carolina Department of Environment and Natural Resources and were pleased to be deemed compliant with RCRA regulations. Nonetheless, we continuously remind hospital staff to dispose of medications in the pharmaceutical waste containers. With this program in place, we are confident we are effectively managing our pharmaceutical waste while helping to protect our environment at the same time.
Mark Allen, RPh, MBA, is the director of pharmacy at New Hanover Regional Medical Center. Mark received his bachelor’s degree in pharmacy from University of North Carolina at Chapel Hill, and his MBA at the University of Southern New Hampshire.
Blake King, PharmD, BCPS, completed his pharmacy residency at New Hanover Regional Medical Center in 2009, and is now the pharmacy manager of compliance and implementation.