[Pharmwaste] Cactus Sink

[William Speenburgh]

I am responding to your question regarding how to legally dispose of
pharmaceutical waste generated by patient care operations and the EXP Cactus
Sink.  

 

EPA and many states are disallowing the practice of flushing waste
pharmaceuticals down the toilet or sink.

 

Disposal facilities acceptance processes and operating permits require a
detailed characterization and inventory describing the wastes that will be
shipped 

 

EPA requires Generators to ensure Hazardous Waste are identified and
disposed of properly.  Mixing of just 1 warfarin tablet with unused patient
controlled drugs, even if it is rendered Unrecoverable and Unusable, makes
the mixture a Hazardous Waste.  If the mixture weighs more than 1 Kg., the
Generator is now considered a fully regulated Large Quantity Generator of
Hazardous Waste.  

 

Since 2014, DEA rules requires patient owned waste to be managed by a DEA
Registrant/Collector or law enforcement in specially designed collection
systems that meet security requirements for placement, installation,
operation and shipment to DEA Registrant/Collector Pharmaceutical Reverse
Distributors.  Waste must be stored in DEA Schedule II vault until waste is
witness destroyed by incineration. Pharmaceutical wastes that do not belong
to the end user (i.e patient) are prohibited. 

 

Over the past several years, the healthcare industry has shown interest in a
product called the Cactus Sink.  Marketed as the ultimate answer to disposal
of pharmaceutical waste generated by hospitals, the Cactus Sink manufacturer
accurately describes its product as securely capturing dispensed unused
pharmaceutical waste and renders it "unrecoverable and unusable" <through
chemical fixation>  This is an effective collection system but it has
serious side effects with disposal abilities:

1.	There is no inventory maintained as to the contents and after
mixing, cannot be verified.  This makes the filled canisters very difficult,
if not impossible, to dispose of.
2.	How does the Hospital totally ensure that the device is used only
for controlled drugs and never contains any hazardous waste?  If the
canister and contents weigh more than 1 Kg. before being used, adding just 1
warfarin tablet (or other "P" Listed product dose) makes the hospital a
Large Quantity Generator of Hazardous Waste
3.	In 2014 DEA finalized rules for the collection of patient
medications from households and Long Term Care Facilities.  The collection
system has strict DEA security specifications and the collectors DEA
Registration must be amended prior to staring the collection. The Cactus
Sink is intended to collect waste pharmaceuticals in a hospital setting
where the waste does not necessarily belong to the patient, violating this
DEA rule. 
4.	The canister can be used for liquids.  Many pharmaceutical products,
particularly liquid preparations, meet the definition of a DOT Hazardous
Material in Transportation (e.g. Excelon - 6.1 Toxic and flammables,
corrosives and oxidizers are quite common pharmaceutical wastes).  While
these may be shipped as a Consumer commodity ORMD as a medicine, there is no
provision to mark those canisters that contain Hazardous Materials as ORMD.
Incompatibility of hazards is an issue potentially causing a dangerous
shipment of mixed flammables and oxidizers, etc. to occur in transit.  

The Cactus Sink is a great waste collection system but needs considerable
effort to make it a viable solution for disposal of the wastes it collects. 

 

If you are interested in a truly better way to destroy your unwanted
pharmaceuticals from the hospital/pharmacy or patient wastes collection and
destruction please contact us about our WasteLink products and services

 

 

William G. Speenburgh,

President

World Class Environmental Resources, LLC

(973) 219-5720

 

WasteLink: Connecting the Missing Link in Reverse Distribution 

 

A Service Connected Disabled Veteran Owned Business

DUNS: 012781816      CAGE Code: 62GD7

 

 

 

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