Addressing Challenging Waste Management Practices

March 2010 - Vol. 7 No. 3

By Deanne Halvorsen

Scrutiny of pharmaceutical waste management practices in the hospital continues to increase, with the EPA, NIOSH, state boards of pharmacy, and The Joint Commission weighing in on various practices. Over the past year, we have seen an increase in recommendations and citations issued to hospitals along with an increase in spending by many hospitals to achieve compliant waste practices.

Previously, many directors of pharmacy were frustrated by the conflicting and often unclear waste management regulations. As a result, the actual practice of waste management in many hospital pharmacies lags far behind the regulations. With increasing awareness of the dangers from improperly disposed medications—and regulatory pressure—it is incumbent upon pharmacy managers to establish safe and proper drug disposal.

The current situation with H1N1 vaccine disposal underscores this issue. When PP&P asked a national sample of directors of pharmacy how they dispose of challenging products, the response regarding the flu vaccine containing D-listed thimerosal (D009) was as follows: the majority (43%) indicated they use the red sharps bin, with another 24% using the regular trash, drain, or yellow chemotherapy-hazardous bins. Only one-third are properly disposing of this product in RCRA-hazardous waste containers. Because the majority of flu vaccines are not returnable, a disposal plan must be in place. Charlotte Smith, RPh, MS, HEM, director of PharmEcology Services, WM Healthcare Solutions, points out that not only do the multi-dose vials of H1N1 vaccine contain sufficient concentrations of the preservative to be defined as hazardous under the toxicity characteristic, but the manufacturing process for some of the preservative-free single-dose vials includes thimerosal, resulting in a finished product that also qualifies as RCRA-hazardous. Therefore, a determination of compliant flu vaccine disposal methods must also include a review of the products’ thimerosal content. For more details on H1N1 disposal guidelines, a News Alert is available on PharmEcology’s Web site,

Current Disposal Methods
Results from PP&P’s national Going Green survey outline the current methods in use for disposing of waste from barium contrast media and oxytocin.


Disposal Guidelines
To determine if a barium contrast agent meets the hazardous waste definition, review its molecular weight, determine the percentage of barium in the barium sulfate molecule, then calculate the amount of barium that would be present in the product and convert it to a mg/L concentration. If the concentration exceeds 100 mg/L, the product may be characterized as hazardous waste, requiring disposal in a RCRA container.

A more precise approach is to review the results of a toxicity characteristic leaching procedure (TCLP), an analytical test that simulates the leaching that occurs in a landfill. If the contrast exceeds the 100 mg/L limit, it is a hazardous waste. “The most cost-effective approach is to request this data from the product manufacturers, who should have it on file,” notes Smith. “Your GPO can be instrumental in this process by requiring the data as part of the contracting process. In the absence of TCLP data, barium contrast media should be disposed of as hazardous waste.”


Disposal Guidelines
Oxytocin is on NIOSH’s list of drugs that should be considered for handling as a hazardous material. Because exposure to oxytocin may affect pregnant employees—including those who are not aware that they are pregnant—each hospital must decide how to handle this product. Policies that should be considered include limiting who can administer this product and requiring the administering staff member to gown and glove. “The most important issue is to ensure that oxytocin is not being disposed of down the drain,” states Smith. “If your non-hazardous drug waste is incinerated at a regulated medical waste incinerator or waste-to-energy facility, this would be an appropriate disposal method. However, if your non-hazardous drugs are going down the drain, oxytocin should be disposed of as hazardous waste.”

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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