Services for Healthcare Facilities

Managing Pharmaceutical Waste

Environmental Responsibility

Although the Resource Conservation and Recovery Act (RCRA) imposes requirements for the disposal of certain pharmaceutical wastes, environmental responsibility extends beyond regulatory requirements. Veolia Environmental Services can help your facility identify Best Management Practices and implement them in your organization.

The results of recent water quality studies indicate that current levels of pharmaceuticals and endocrine disrupters in the water supply are adversely affecting the reproductive cycles of aquatic species and may be impacting human health and development. One way these drugs have entered our water sources is through historical disposal practices by healthcare institutions.

The Precautionary Principle is an approach to environmental practices that is under consideration by the Science and Environmental Health Network as a basis for environmental and public health policy and is gaining acceptance throughout the scientific community. This approach requires the proponent of an activity that appears to have adverse environmental effects to bear the burden of proving that the activitiy does not have deleterious consequences. Every healthcare institution must determine whether is pharmaceutical disposal practices meet the Precautionary Principle.

Veolia Environmental Services understands the federal, state and local environmental requirements and assures that our customers are in compliance. We are committed to help our healthcare customers meet their environmental goals and incorporate environmentally safe practices into their daily routines.

Manage Waste, Reduce Liabilities

We begin with an on-site waste consultation to assess your current status of compliance. By evaluating your existing systems, including a formulary review, we can target those areas where your facilities may be exposed to regulatory action. Our systems allow on-line waste shipment tracking for quick access to your waste streams and manifests - track disposal routes, transport methods and the final disposal location.

Technical Expertise

Veolia Environmental Services provides thorough, expert service in all areas affecting pharmaceutical waste. Our field technicians undergo extensive and continual training to assure that they are current with all safety, health, and environmental requirements. We also offer staff training to minimize both the costs and risks associated with disposal of pharmaceutical waste to assure that everyone understands and follows established procedures to avoid the risk of regulatory action. Read about our collection program for unused medicine.

Regulatory Requirements

When the Resource Conservation and Recovery Act (RCRA) was enacted in 1976, industrial waste was the primary focus in controlling waste disposal activities.  Management of hazardous pharmaceutical waste is an area that was not targeted at that time but definitely falls under regulatory purview.  Several regional offices of the US EPA have become aggressive in inspecting healthcare facilities and enforcing hazardous waste regulations through fines.  State regulations may be more stringent than federal requirements and vary by state.

Approximately 5% of commonly used pharmaceuticals are defined as hazardous waste under RCRA and include nine chemotherapeutic agents, epinephrine and warfarin.  These regulations have not been updated in over 30 years, and many more drugs that are not subject to the regulations are equally hazardous.  Included in this category are over 100 newer chemotherapy drugs, endocrine disruptors and drugs meeting NIOSH hazardous drug criteria.  Best Management Practices dictate that these drugs be manageed as though they were subject to regulation under RCRA.

Disposal of drugs like antidepressants and antibiotics is not regulated by RCRA but state and local agencies may impose certain disposal restrictions.  Best Management Practices would require disposal of any unused pharmaceuticals through destruction technologies to avoid contamination of water sources.

The Joint Commission has established standards regarding hazardous materials and wastes that accredited institutions must follow.  These standards require healthcare institutions to develop a written management plan for hazardous materials and to maintain an inventory list which identifies related wastes.

Healthcare institutions are directed to implement processes that minimize improper disposal of pharmaceutical wastes.

Our professional staff will help your organization determione relevant regulatory requirements and will identify additional steps to follow under Best Management Practices.  In each case, we will provide cost effective, environmentally friendly solutions.

Complex Waste Streams

Pharmaceutical waste is complex and reflects the wide range of chemicals that comprise the pharmaceuticals themselves.  Activities that generate this waste may include:  spills, unused preparations, IV preparations, outdated pharmaceuticals, patients' medications, unit doses from repacks, and partially administered vials, syringes or IV's.

Typically, a hospital maintains 2,000 to 4,000 items in its formulatory.  Each item must be evaluated to determine whether special handling is required under federal and state hazardous waste regulations.

Facility Classification

RCRA regulates healthcare facilities, based on the quantity of hazardous waste that they generate during one calendar month.  A Large Quantity Generatory (LQG) is defined as one that generates 1 kilogram of P-listed waste during one month.  This definition translates into a few one liter bags prepared with a P-listed drug for ICU or OR but discarded.  The most comprehensive RCRA requirements are applied to LQGs.