Going Green 2009: The Struggle toward Compliance

December 2009 : Going Green - Vol. 6 No. 12

By Deanne Halvorsen

Just as we are becoming more aware of the growing dangers from improperly disposed medications leaching into our drinking water supply, so are the many regulatory bodies that just as we are becoming more aware of the growing dangers from improperly disposed medications leaching into our drinking water supply, so are the many regulatory bodies that oversee pharmacy. The resulting regulatory pressure is driving many changes in approaches to pharmaceutical waste management.  In a bid to better understand where pharmacy practice stands today, Pharmacy Purchasing & Products conducted the second annual Going Green survey of health-system pharmacy waste processes.

Survey Design
In the fourth quarter of 2009, PP&P polled a random, nationwide sampling of health system directors of pharmacy. We asked about their pharmaceutical waste management practices, expenditures, regulatory compliance, and staff training methods. Responses were solicited via e-mail, and we received a total of 260, yielding a confidence interval of 5.94 (95% +/-5.94) based on the total population of DoPs nationwide.

We intentionally surveyed a random sampling of DoPs, not just readers of PP&P to ensure our data reflects trends across the whole of hospital pharmacy practice. We were pleased to learn that 61% of DoPs nationwide use PP&P as a resource for information on pharmaceutical waste management.

Investing in Compliance
Despite an overall tightening of hospital budgets, the commitment to environmental protection in general and to compliant pharmaceutical waste management in particular increased this year. This was backed up by significant growth in spending in 2009 and an expectation that spending and the commitment to compliant waste management will continue to increase over the next few years. In fact, 66% of DoPs would consider purchasing off-contract or even higher priced products to meet their institution’s environmental objectives.

Investing in developing compliant practices became more imperative this year as EPA and state inspectors have demonstrated increased comfort with the regulations and issued significantly more recommendations and citations to hospitals. Forty-five percent of inspected facilities have received a recommendation or been cited. Given that RCRA violations can result in fines of up to $37,500 per violation, per day, developing the expertise necessary to manage pharmaceutical waste is crucial not only to ensuring a facility’s environmental responsibility but also its financial health. Nonetheless, 43% of hospitals have no plan to establish a budget for managing pharmaceutical waste. Without a solid financial commitment from pharmacy and administration, attaining compliant practices will be a daunting assignment.

Challenges for Pharmacy
Pharmacy is well aware of the challenges they face in achieving compliance given the complexity of the regulations and a lack of in-house expertise. Most facilities report that their RCRA-regulated and non-hazardous waste practices are not in compliance, although hazardous chemotherapy and controlled substance waste management compliance rates fared somewhat better.

DoPs demonstrated increased awareness of proper waste stream disposal for many hazardous drugs this year. Fewer facilities are disposing of warfarin >0.3 mg in the regular trash and red sharps bins, for example. However, those properly using RCRA-hazardous containers for disposal of this P-listed product and other hazardous drugs are still in the minority.

A major impediment to establishing compliant practices is the dearth of expertise among pharmacy staff. Most DoPs report that their staff is not sufficiently knowledgeable about hazardous pharmaceutical waste practices. This is not surprising given that only 27% of facilities provide formal education on pharmaceutical waste management. Those pharmacy leaders who do provide training have recognized the value of comprehensive education and provided this training to staff much more regularly this year. Of note, the small number of facilities that require risk managers and administrators to receive waste training along with the clinical staff report much higher rates of compliance for RCRA-regulated waste.

In addition to the potential cost of fines, the potential cost to employees’ health and our environment from improper waste stream disposal should be deemed completely unacceptable by pharmacy and the hospital administration.  Just as pharmacy is responsible for ensuring patients receive safe and effective medication, pharmacy must also lead the drive for ensuring safe and proper drug disposal.



Digital Edition

PP&P is now available online in the exact layout and appearance of the print edition, and includes more interactive features, such as the ability to access websites and request information with the click of a mouse.  To view this article in the digital edition, CLICK HERE.


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