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

[Janet Brown]

Practice Greenhealth has been offering compliance and best management
guidance on pharmaceuticals in health care.  Check out our webinar archives
over the past few years for a variety of educational events.  The last one
was held on May 15 and included an update on the Blue print guidance
document co written by Charlotte Smith and Eydie Pines, a case study by
Albany Medical Center, report out by US Geological Survey and Stericycle
with options/support.

Here is a link to the archives 

http://www.practicegreenhealth.org/tools/webinars/archive/

Here is a link to the guidance document:

http://cms.h2e-online.org/ee/hazmat/hazmatconcern/pharma/

The Joint Commission has also added language specific to the management of
pharmaceuticals:

Standard MM.01.01.03 - The organization

safely manages high-alert and hazardous

medications.

(EP 4) The hospital minimizes risks associated with managing

hazardous medications.

This is in addition to the Environment of Care Standards for Hazardous
Materials an d Waste that is already in place.  The formulary should be in
place as part of OSHA's Hazard Communication Standard already.

I agree with you, though, that most hospitals still do not have compliant
programs in place.  But of the hospitals that we work with (about 700) -
management of pharmaceuticals IS on their radar.  The challenge is the
complexity of the regs, not only on a federal level but state to state and
the high cost of the best management approach (antibiotics and such) and
dual wastes.  Check out the archives for some examples of the varying ways
hospitals are collecting pharmaceuticals.  Some collect all meds and have
them sorted at the back end, while others use a labeling system and
segregate the Ps and Us and characteristic meds in a black bin and the
nonregulated pharmaceuticals in a blue bin, that goes to a regulated medical
waste incinerator, at a cheaper rate than the hazardous waste incinerator.
The bulk chemo goes to a haz waste incinerator, while the trace goes to a
regulated incinerator.  Duel wastes (both haz & regulated) go to the
incinerator that is licensed to handle both.  And the DOT governs all of
this as well.  Some are addressing the acutely toxic drugs as a phase one
and then moving on to other drugs from there.  The case studies both from
Albany Med and the Minnesota Technical Assistance Program (another archived
webinar) speak to the financial incentive of pollution prevention through
close scrutiny of the wasted or returned meds to change work practices,
purchasing, unit dose etc.. to make less waste.

I don't have the answers to all of your questions but I hope this helps a
little bit.  Please check out both the blueprint and the archived webinars
for more details.

Janet Brown

Director, Sustainable Operations

Practice Greenhealth 

Po Box 3366

Amherst, MA 01004

866/598-2110

413/253-0254

jbrown at practicegreenhealth.org

www.practicegreenhealth.org

 

Janet is on the steering committee of the Green Guide for Health Care.
www.gghc.org.  

 

 

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of William More
Sent: Monday, June 22, 2009 10:58 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Re: Pharmwaste Digest, Vol 44, Issue 12

 

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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