In light of the recent AP report on US drinking water tainted with pharmaceuticals and increasing regulatory fines, the need to establish comprehensive pharmaceutical waste management programs has become a pressing issue for pharmacy. Achieving regulatory compliance by identifying the appropriate waste streams for drug waste and managing the segregation process must be a priority for all health systems. As the resident in-house pharmaceutical experts, it is key that pharmacists not only participate in this process, but that we actually drive the change. Not because we have to, but because it is the right thing to do.
Facilities that improperly dispose of drug waste run the risk of damaging the environment and incurring significant regulatory fines. RCRA violations for example, can result in fines of up to $32,500 per violation, per day. In addition, OSHA’s Hazardous Communication Standard requires that all employees working with hazardous chemicals receive training and PPE; should they not receive these, they have the right to sue their employer. Outsourcing your waste disposal may simplify some of your processes, but you cannot outsource your responsibility to assure compliant procedures are followed. Just as you train your hospital staff in proper and safe disposal methods, you should think about educating outsourced employees as well. Remember, you own the waste you generate until it is 100% destroyed and the burden of liability for the safety of outsourced employees falls on the hospital.
Pharmaceutical Waste Management Practices
In the survey results, it is heartening to see that a clear majority of DoPs are aware that collecting all pharmaceutical waste, including hazardous and non-hazardous, in one container on the floor and segregating it on the loading dock is both poor practice and illegal. However, the survey results also demonstrated a wide range of disposal methods currently in use, and many facilities reported improperly disposing of drugs, such as putting warfarin >0.3% (RCRA P001) in the regular trash. Just as pharmacy does an excellent job reviewing drugs to be on formulary, we need to put the same effort into drug disposal and worker safety.
Making a commitment to properly managing pharmaceutical waste requires a budget commitment as well. Currently, very few hospitals have a line item in their operating budget for managing pharmaceutical waste. Of those who do, most are committing very few dollars. Consider, for example, that 200-bed hospitals spend $7,500 annually, on average, to manage their pharmaceutical waste. For a hospital with an annual drug budget of $5 million, that means approximately .002% of the drug budget is being spent to manage the resultant waste. In addition, I find it alarming that 33% of respondents have no plans to establish a budget for managing pharmaceutical waste. We have to do better than this. Compliant waste management cannot be attained without the commitment of pharmacy, hospital administrators, and resources.
Waste Management Resources
Not surprisingly, many survey respondents complained about a lack of good sources for training staff on compliant waste disposal. I recommend starting with the ASHP Advantage’s ACPE accredited Pharmaceutical Waste Management Issues and Options for Health Systems, updated in October 2008, which is supported through an educational grant from Vestara. For more information, visit http://symposia.ashp.org/pharmawaste. In addition, an excellent resource guide on pharmaceutical waste management strategies and audit worksheets are available free of charge at www.safersolutions.org. Consider including pharmaceutical waste management in your annual hospital safety review to ensure your staff is continually engaged. Achieving compliant pharmaceutical waste management is imperative for the safety of our water supply and our health, and pharmacy needs to lead this process. We should not wait for regulations to drive an initiative, especially one we can control.
Firouzan "Fred" Massoomi, PharmD, FASHP, has served as the pharmacy operations coordinator at the nebraska Methodist Hospital for the past 11 years.
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