Balancing Commitment with Action

December 2013 : Going Green - Vol.10 No. 12 - Page #1

Embracing environmental stewardship is a popular position that receives support both from hospital staff and the community at large. It is probably impossible to find a hospital administrator anywhere in the US who would deny the importance of taking a responsible approach to environmental management. But this commitment does not always translate into highly effective pharmaceutical disposal programs. Rather, pharmacy directors are often stymied in their efforts to implement proper disposal methods for pharmaceutical waste, particularly for products such as fentanyl patches, glycopyrrolate, and warfarin.

Survey Design
To understand how pharmacy responds to the complexity of waste management regulations, PP&P polled a random nationwide sample of health system pharmacy directors. This is the sixth year we have conducted this poll. Responses were submitted via email, with pharmacy directors from 453 facilities responding, yielding a confidence interval of 4.42% (95% +/-4.42) based on the total population of pharmacy directors nationwide.

We intentionally surveyed a random sample of pharmacy directors, not just our readers, to ensure the data reflects trends across the whole of hospital pharmacy practice. Thus, we were pleased to learn that 76% of pharmacy directors rely on PP&P for waste management information. 

Compliance Challenges
Commitment to compliant practices continues to increase, but the number of facilities willing to purchase off-contract or spend more to meet their environmental objectives has not grown. Commitment is more likely to be reflected in the adoption of written P&Ps, as well as plans to add a line item for pharmaceutical waste to the operating budget.

Backing up this commitment with improved compliance is important, as inspections targeting waste practices are increasingly common; just over half of all facilities have had their environmental practices inspected over the past three years. Like the EPA and CMS, state boards of pharmacy, accreditors, and state departments of health are quite likely to investigate environmental practices during an inspection. Few inspections result in citations, but recommendations are increasing.

RCRA compliance is a key area of focus for inspectors, and given the complexity of these regulations, has the potential to become a significant problem for pharmacy. Many pharmacies have yet to achieve full compliance with RCRA regulations, and progress toward this goal has been slow. While almost three-quarters of facilities have implemented a RCRA-characteristic waste program, just 60% of hospitals deem their programs fully compliant.  

Ensuring Non-Recoverability of Controlled Substances
Non-hazardous and controlled substance wastes also challenge many pharmacy directors striving to implement fully compliant waste practices. It is vital to be aware of how your non-hazardous waste is ultimately disposed; options are very different for waste disposed via landfill versus medical waste incinerator. 

Controlled substances pose another conundrum, given the lack of federal guidance. Disposing of controlled substances via the sewer is not only a poor environmental practice, but also is forbidden in many states. This creates a challenge, as the DEA has yet to delineate alternative, non-recoverable disposal options. 

Staff Training
While the complexity of the various regulations is challenging for many pharmacy directors, providing effective staff training is the prime stumbling block for many facilities. Hospitals also are often deterred by a dearth of storage space and a lack of in-house expertise. Overcoming these challenges requires support from administration, be it funding for additional training or the allocation of sufficient space for waste storage. 


Pharmacy’s Green Responsibility
Ultimately, pharmacy is responsible for the cradle-to-grave management of all medications within the facility. By extension, the hospital administration is responsible for supporting this approach. Working collaboratively to ensure compliant waste disposal will benefit the organization while also improving our environment.


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