Pharmaceutical Waste Disposal and Best Management Practices (Part 1 of 2)

In recent years, trace pharmaceutical wastes have been detected in waterways and drinking water in many metropolitan cities throughout this country.   The risks posed by these pollutants are not entirely known.   Of foremost concern are the potential for human resistance to antibiotics in our drinking water or potential endocrine system disruption from steroids in drinking water.   Drugs may enter our municipal water systems through improper disposal methods (e.g., flushing down the sewer or leaching from landfills).   The term “unused pharmaceuticals” applies to partially used or empty dispensers containing material or residue (e.g., IV bags).  Another source of contamination is expired pharmaceutical or patient excreted materials, which are not considered “unused pharmaceuticals.”

Under the EPA Draft Proposal, hazardous pharmaceutical wastes are to be added to the Universal Waste Rule.   Generators may manage pharmaceutical waste as universal waste.   This process will streamline collection, disposal and handling.   More importantly, it should improve compliance to better ensure that these substances do not find their way into our drinking water.

If this rule is finalized and adopted by state agencies, facilities may begin to manage pharmaceutical waste under the Universal Waste option.   A hazardous waste generator would now be a universal waste handler with respect to unused pharmaceutical wastes.  Handlers under the universal waste regulation have increased waste volume thresholds, greater accumulation time on-site (one year vs. 90 or 180 days), no manifests with simplified sorting, handling and training requirements.

The existing RCRA regulation is challenging for healthcare organizations.   RCRA-listed waste products require meticulous documentation, need to be sorted and then must be sent to a properly authorized disposal facility.  RCRA-listed waste must be dealt with in a waste stream that is separate from other types of pharmaceutical waste.  The EPA wants to ensure that pharmaceutical waste is managed in a responsible manner and pharmaceuticals are not going down the sewer drain.  Facilities will still be liable for ensuring that the unused drugs reach an authorized disposal facility.  There will still be still cradle-to-grave responsibilities to ensure that pharmaceuticals are not dumped illegally.

The proposed universal waste rule amendment to include pharmaceuticals will be a benefit for health facilities because it will simplify things, and should save pharmacies, hospitals, physicians, outpatient centers, vets, morgues and reverse distributors significant dollars and help to keep drugs out of our water supply.   In part two of this series, we will discuss best practices for pharmaceutical waste management.

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