[Pharmwaste] Re: Pharmwaste Digest, Vol 44, Issue 12

William More wamore at gw.dec.state.ny.us
Mon Jun 22 10:57:41 EDT 2009


So what is the present compliance rate with our Hospitals Pharmacies with the RCRA - Hazardous waste regulations? 
How are they achieving Hazardous Waste Determinations? How do they segregate wastes, and when?
How many have a program that know where the stuff that the reverse distributors don't want to take go?  What happens to the waste - contaminated packaging - that comes from dispensing drugs that can be a "P" waste?  Do the reverse distributors(RDs) tell the hospitals about these materials? Do they, the RDs, take these back?
Does that make them a TSDF?  Are they manifested?  What mechanisms are the Hospital Pharmacies using to recover these materials from the patient floors?
What are the RDs doing with those materials that are never credited? The partials that can't be reused because that are not factory sealed?  Those materials that are so far out of date?  The RDs know what they are. Do they pick them up anyway. Does that make them a TSDF? Are they manifested?
 
Have all of the Hospital Pharmacies had their Formulary,(likely stocked Drugs), reviewed as to which ones can be a Hazardous Waste when unusable ,unreturnable, un credited, when a waste. Have they looked for characteristic Hazardous Waste? Mercury compounds that may be used as a preservative? Metals in vitamins or dietary supplements? Alcohol or CFCs in inhalers?
 
What are we seeing when we look at these questions???????
 
 
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