There is a fascinating complexity surrounding pharmaceutical waste management, from the multiple layers of often-conflicting regulation to the moral challenge of leaving clean waterways for our children. As pharmacy must resolve these conflicts to develop compliant practices and avoid the threat of significant fines, we have seen the commitment to waste management increase significantly over the past few years. This dedication is reflected in the growth of resources, including increased budget allocation, staff training, and equipment purchases focused on improving disposal methods. Here at PP&P, we have tracked these trends over the past few years in our annual Going Green survey, the results of which are published every December. In addition to monitoring these macro trends, we also track actual waste practices in hospitals nationwide.
The most recent survey brought good news in terms of hospitals’ practices in addressing hazardous products. On the pages that follow, we share the current nationwide trends in managing some of the most challenging pharmaceutical wastes. As the data demonstrate, hospitals managing RCRA-hazardous waste in a compliant manner are generally in the minority. However, there are strong positive trends in facilities moving to adopt these approaches. Just as pharmacy’s commitment to compliant waste management remained strong despite the financial challenges of the past few years, we expect compliant practices to become widespread in the coming years.
Challenges with Dual Waste Requirements
When a product is both hazardous and controlled, pharmacy has historically struggled with determining the correct approach to managing this waste. Previously many pharmacy directors complained they had no choice but to dispose of these products down the drain to meet the DEA requirement of rendering a controlled substance unrecoverable. This is a specious position at best, given that the DEA does not define “rendered unrecoverable” as sewering the product. In fact, many states (including Florida, California, and Washington) explicitly forbid dumping such waste into the water supply via the sewer system. In addition, the EPA has fined many health systems for drain disposal of hazardous pharmaceuticals.
The most logical solution to this challenge is to avoid generating waste in the first place. Reviewing your ordering practices with this goal in mind can lead to significant reductions in waste generation. For example, if priority is placed on aligning the size of morphine sulfate vials stocked to the size most commonly ordered—as opposed to prioritizing according to the initial product cost—the long term benefit from the resultant waste reduction is a plus for the budget. Once the cost to waste a product is included in the purchasing decision, the argument for smaller vial sizes and just-in-time inventory becomes apparent.
Clearly, pharmacy is recognizing the importance of managing these dual wastes as hazardous. There is a strong trend toward disposing U-listed chloral hydrate waste via RCRA-hzardous containers as noted in the chart to the bottom right. While the practice is less widespread for morphine sulfate waste, we do expect the trend to continue to increase.
Deanne Halvorsen is the editorial director at Ridgewood Medical Media, publishers of Pharmacy Purchasing & Products, and can be reached at firstname.lastname@example.org.
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