FW: [Pharmwaste] How is warfarin disposed at your Hospital?

[Tenace, Laurie]

Please note this email did not originate with me.
Laurie

From: Miller, Fred [mailto:millerfl at wsu.edu]
Sent: Wednesday, November 13, 2013 11:31 AM
To: Jeff Hollar; 'William More'; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] How is warfarin disposed at your Hospital?

Re hazardous waste treatment: RCRA rules allow for generators to treat their own wastes in containers or tanks without a permit.  Some states (i.e. Washington<https://fortress.wa.gov/ecy/publications/publications/96412.pdf>) have gone so far as to publish guidance on how this can be accomplished while other states like California specifically prohibit most treatment by generator activities.

That said, unless the generator can demonstrate through testing or generator knowledge that treatment is effective and does result in non-hazardous residuals, they are still bound to dispose of the resulting materials as regulated waste.  A quick review of the literature leaves me unconvinced steam autoclave conditions would result in effective treatment of warfarin.  In fact, introducing P001 wastes into the autoclave would likely result in the entire load and any effluents which contacted the load designating as P001 waste.  Unless they have permission from their POTW to discharge such effluent to the sanitary sewer they are violating both RCRA and CWA rules.  Similarly, any resulting solids disposed as MSW would be a violation of RCRA.

Note the melting point and solubility data here warfarin data<http://www.chemicalbook.com/ChemicalProductProperty_US_CB0413732.aspx>   Absent addition of a strong mineral acid or base the data lead me to believe no reaction occurs under steam autoclave conditions.  If anyone knows of literature which contradicts my understanding of the chemistry I'd appreciate seeing it.

Fred

From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jeff Hollar
Sent: Wednesday, November 13, 2013 6:54 AM
To: 'William More'; pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: RE: [Pharmwaste] How is warfarin disposed at your Hospital?

Per EPA, wouldn't this be considered "treatment" of hazardous waste?  I doubt the facility is licensed as a TSDF (Treatment Storage and Disposal Facility).
Jeff Hollar
President
PharmWaste Technologies, Inc.
4164 NW Urbandale Dr., Ste A
Urbandale, IA 50322
515-276-5302 (general)
515-331-7310 (direct)
515-360-9785 (cell)
www.pwaste.com<http://www.pwaste.com/>

From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of William More
Sent: Wednesday, November 13, 2013 8:12 AM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] How is warfarin disposed at your Hospital?

I recently came across a Hospital during a Hazardous Waste Inspection that claims steam sterilized Warfarin contaminated containers are no longer "P Waste."  Has anyone seen this? or records of analysis that can back this up?  I'm waiting on submission of test results, but thought I would see if anyone else has heard of this.
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