The effort to manage medication waste in an environmentally responsible manner, while also reducing the risk of diversion, can pose significant challenges for pharmacy. In addition to complying with RCRA regulations, DOT has specific transport requirements and state regulations are being revised at a rapid rate. Staying abreast of evolving regulations and disposal options requires an ongoing, dedicated effort. Assigning a point person to develop regulatory expertise in medication disposal and spearhead development of a compliant program is highly recommended.
Once a compliant program is in place, comprehensive staff training must ensue. Be sure your employees understand the environmental risks and financial penalties that can result from improper disposal. After the initial training, consider developing refresher courses and providing supportive signage at common points of disposal. Your waste vendor may serve as a resource for interpreting regulations and may also be able to provide support in developing training programs. Regular waste audits can be utilized to measure your program’s effectiveness and ensure ongoing success.
Fortunately, just as state laws are tightening disposal options, an assortment of disposal tools are commercially available, including software solutions that manage waste classification, assessments of risk, and disposal documentation; recall and reverse distribution services; as well as a variety of containers that render controlled substances irretrievable.
Rx Destroyer from C2R Global Manufacturing utilizes a patented, quick-acting formula that begins neutralizing medications on contact, minimizing opportunities for drug diversion and abuse while helping to protect local water supplies. Users simply add medications, shake, and dispose in common trash or follow their facility’s compliance regulations. The system’s formula is 100% natural and meets the DEA’s definition of non-retrievable. Due to differences in state laws, C2R Global Manufacturing maintains waste hauler and mail-back partnerships for compliance guidance and certification.
From C2R Global Manufacturing
Stryker’s Cactus Smart Sink System and PharmaLock OR are controlled substance waste management systems that securely capture unused pharmaceutical waste and render it unusable and non-retrievable, ensuring discarded medications do not end up in the wrong hands or negatively impact the environment. Designed for pharmacies and patient rooms, the Smart Sink accepts both liquid and solid pharmaceuticals in the form of capsules, tablets, or patches. Its technology alerts the user when cartridges are full and when the system has been opened.
PharmaLock OR facilitates remote wasting and is most commonly found in OR settings, but can be used anywhere liquid pharmaceuticals are administered. It can easily be mounted to a cart using available hardware and has an antimicrobial coating to maintain sterility. Both products help reduce the opportunity for drug diversion and bring facilities into compliance while providing a green waste solution.
Stericycle’s CsRx Service is designed to help hospitals enhance existing security procedures for disposal of controlled substance waste in a safe and secure manner. Each CsRx container includes a deactivating agent and deterrent, which require water to activate. The deactivating agent and deterrent permanently alter the substance’s chemical condition, rendering it non-retrievable; this includes pills, patches, tablets, and IV solutions. Stericycle’s proprietary containers are designed with a one-way disposal path that allows substances to enter the container but not be removed, preventing the possibility of diversion. The unique lid opening is designed to prevent a sharp, vial, or ampule from entering the container so that the deactivating agent can interact with the disposed controlled substance.
The CsRx includes lockable wall brackets at no additional charge. All controlled substance waste is incinerated at a permitted Stericycle facility, keeping these products out of our communities and waterways. CsRx Service provides a secure solution for disposing of controlled substance waste, keeping patients and staff safe.
The RxDestruct waste disposal system is the result of partnership with Clear River Enviro, Southwest Research Institute, Campbell University College of Pharmacy, and Agile Technology. The team utilized a scientific approach to digesting chemical compounds that can be executed in a patented device smaller than a desktop printer. The size and configuration of the system allows for installation wherever pharmaceuticals are handled, and can be directly installed with standard plumbing connections, allowing for immediate disposal into the sewer following chemical destruction. RxDestruct is also available in a self-contained, portable version.
From RxDestruct/Clean River Enviro, Inc.
RASMAS from Inmar is a user-friendly, Web-based service that improves patient safety by tracking product recalls and providing timely alerts. Helping to expedite the removal of potentially harmful products before patient care is impacted, the system can help reduce legal risk, simplify regulatory reporting, and enhance the recall management process.
The system offers aggregated and uniform recall notifications; reduced time from receipt of product notifications to recall resolution; transparency that provides insight into recall remediation performance; traceability that captures actions and data collection for response to regulator audits; and enterprise management of the recall process and remedial actions taken through real-time reporting.
Providers and suppliers can join the RASMAS community to automate product alert distribution and electronically participate in remediation activities.
MedSafe from Sharps Compliance is a medication collection and disposal solution designed for hospitals with on-site pharmacies that aims to prevent prescription drug abuse and to keep the water supply safe. Meeting all requirements for a DEA collection receptacle program, MedSafe provides a safe and convenient place for patients and visitors to bring their unused or expired medications, including controlled substances (Schedules II-V), for safe collection and proper disposal.
By helping to remove unused medications from homes, hospitals can prevent pharmaceuticals from circulating into the community water supply, or worse, being diverted for unintended use by others in the home. Flexible pricing options are available for this system, which offers prepaid return shipping for inner liners, comingled collection of controlled and non-controlled pharmaceuticals, and destruction of drugs by incineration to meet DEA requirements.
From Sharps Compliance
PharmaLink’s Reverse Distribution Services provide ethical and transparent pharmaceutical returns services, including compliant disposal and optimized reporting to the entire spectrum of pharmaceutical classes of trade. Services include a full complement of on-site and mail-in pharmaceutical returns services as well as recall and proof of destruction capabilities. Personalized customer service supports recall and returns processing as well as inventory and receivables analysis.
USP <800> Systematized from WMSS PharmEcology Services offers tools that can be customized to any organization, including an assessment of risk document that also includes drugs on Tables 2 and 3 of the NIOSH Hazardous Drug List; a worksheet template documenting pharmacy’s containment strategies, work practices, and administrative rules; and a detailed checklist of USP <800> requirements including the facility’s state of readiness, both as a worksheet and a method of proof during an audit or survey. Using an inventory analysis based on the facility’s 12-month purchase history, PharmEcology’s USP <800> analysts can create a default assessment of risk for drugs whose handling requirements are uniform across the health care spectrum, enabling pharmacy to focus on the drugs and procedures that are unique to its own organization. A 4-hour on-site training workshop is offered, wherein PharmEcology experts meet with your team to complete an analysis of all the requirements of USP <800> as well as to document progress.
From WMSS PharmEcology Services