[Pharmwaste] healthcare wastes in sewer

Catherine Zimmer zimme053 at umn.edu
Tue Feb 7 14:46:02 EST 2006


Hi all,
Time to chime in on the lack of attention to discharges of all sorts of 
chemicals to the sewer by healthcare facilities.  While healthcare 
facilities have knowingly sewered many things, I think they have been 
naive in thinking there is no problem.  And, at least in MN,  wastewater 
plants have basically turned a blind eye.  Not only have pharmaceuticals 
been hitting the drain, but other not so swell stuff such as formalin, a 
combustible liquid (methanol and formaldehyde, a carcinogen), 
disinfectants, sterilants, alcohols, solvents, stains, all sorts of 
other lab waste, thimerosal, etc. 

Let me quote for you some hazardous waste inspection notes, these are 
statements made by healthcare staff regarding disposal of various drugs 
and hazardous chemicals:

"Surgery:  antibiotics, potassium disposed of into the sewer, used 
syringes with remaining material are disposed into the sewer, alcohol is 
disposed of into the sewer."
"ICU:  antibiotics poured down the sewer, half used bottles of 
nitroglycerin disposed of into the solid waste."
"Pharmacy:  waste pharmaceuticals are disposed of into the red bag, down 
the drain..."
"Laboratory:  hematology analyzer, straight plumbed to sewer, chemistry 
analyzer, straight plumbed, microbiology stains to the sewer, sulfuric 
acid mixed with urine poured down the drain..."
"Medical Services:  IV bags with pharmaceuticals are disposed of to the 
sewer."

These practices are the day to day routine of waste disposal not only 
for hospitals, but other industries sewer a lot of chemicals, too as do 
households.  Most of these chemicals are probably not treated by 
wastewater plant, most of them are not tested for in the effluent, so we 
don't know for sure. 
 
But the USGS study shows lots of chemicals are in our surface waters, 
indicating they are not being treated at the plant.  Animals that live 
in water are getting sick and dying at alarming rates, e.g. frogs, fish, 
whales...--

In the interest of public health, environmental health and protection of 
wildlife who have to live in our water discharges, the brakes need to be 
put on, by healthcare, the POTW and most everyone, else, too. 

Catherine Zimmer
Health Care Specialist

Minnesota Technical Assistance Program
University of Minnesota
612/624-4635, 800/247-0015
http://www.mntap.umn.edu

Helping Minnesota businesses maximize resource efficiency, prevent pollution and reduce costs.



Gilliam, Allen wrote:

>H2E -- Hospitals for A Healthy Environment Info Exchange Listserve
>(h2e at email.sparklist.com)
>
>No ramblings there Ross!  You're "on the button"!!!  Especially your items #1 below.
>
>To further confuse/clarify for the non-regulators out there, the state of Connecticut IS "the city" as their STATE pretreatment program [40 cfr 403.10{e}] regulates (as deemed appropriate) indirect, non-domestic dischargers FOR their state's publicly owned w.w. treatment systems.  There are 4 other states in the union that have chosen this "proxy" method of implementing/enforcing the CWA's pretreatment requirements.
>
>Most all other (~40?) states (that EPA's delegated the CWA's National Pollutant Discharge Elimination [key word here] System [NPDES]) have chosen to delegate implementation of the pretreatment program requirements directly down to their cities' level.  
>
>Clear as filter press sqweezins now?
>
>I know there's other state pretreatment coordinators AND some EPA HQ's folks following these listserves and am confused by their silence.... 
>
>Allen g 
>
>
>
>-----Original Message-----
>From: Ross Bunnell [mailto:ross.bunnell at po.state.ct.us] 
>Sent: Tuesday, January 24, 2006 9:20 AM
>To: Gilliam, Allen; h2e at email.sparklist.com; gressitt at uninets.net
>Cc: pharmwaste at lists.dep.state.fl.us
>Subject: [Pharmwaste] RE: [h2e] RE: any legislation/ordinancesbanningdisposal of pharmaceuticals to sanitary
>
>
>To all:
>
>Pardon me for this response being somewhat off-target for the original question, which focused on a municipal ordinance, but I think it is relevant to the overall discussion on the Pharmwaste listserve.
>
>Here at the Connecticut DEP, the staff that have been primarily involved in the Pharmaceutical waste issue thus far have been our waste program and our P2 staff.  CT DEP's water staff have thus far had only limited involvement.  And, when we invited Charlotte Smith of PharmEcology to speak to the Department a few months ago, is was emminently clear that the majority of our water program staff (and by that I mean the NPDES and Pretreatment program inspection, enforcement, and permitting staff) were almost completely unaware of the issue.  Some were surprised (and shocked) that it was standard practice for some medical care facilities to dump pharmaceuticals down the drain, and indicated the following:
>
>(1) under Connecticut's incorporation of the federal Clean Water Act programs, this dispsoal would not be allowed, under the principal that ony wastewaters (and not concentrated wastes) may be discharged to the sewer; and,
>
>(2) the discharge of pharmaceutical wastewaters to the sewer would most likely require a state pretreatment discharge permit.  This permit could be in the form of a site-specific, individual permit, or a state-wide "general" permit for this specific discharge at any location in the state that discharges it, registers for the general permit, and meets the terms and conditions of the general permit.
>
>Being a waste program person, I don't know if this interpretation is unique to CT or can be adopted by any state that is authorized to operate the Clean Water Act pretreatment requirements in lieu of EPA.  Nevertheless, my experiences with our water staff has led me to a number of conclusions, namely:
>
>(1)  The water permitting and enforcement staff (in CT at least), have not fully gotten their arms around this issue yet, and are somewhat further behind on the learning curve than the waste and P2 flolks.
>
>(2)  It seems to me, having monitored the Pharmwaste listserve for some time now, that there appears to be an under-representation by water permitting and enforcement types on the listserve, and that we may wish to reach out to them and more aggressively engage them in the dialogue.
>
>(3)  The Clean Water Act programs (especially the pretreatment rules) could provide an excellent vehicle for addressing the drain disposal issue, at least at non-residential sites (e.g., health care provider facilities), where most of the "bulk" drain disposal occurs (if not the overall greatest volume of such disposal, which I have to suspect, would remain households (it seems to me that local collection events, and not necessarily a sewer ban, are the most effective way to deal with the household material)).
>
>(4)  The obvious conflict between the Clean Water Act requirements and DEA requirements for the disposal of controlled substances is clear under this analysis, and screams for resolution at the federal level (i.e., between EPA and DEA).
>
>Just my thoughts.  Sorry for rambling.
>
>  
>
>>>>"Stevan Gressitt" <gressitt at uninets.net> 01/23/06 10:39PM >>>
>>>>        
>>>>
>Apologies for being late in replying but I had been saving this for when I had a few minutes to go over the regs. I'll defer on those for now. 
>
> 
>
>At the bottom where you comment on the economics. Could I suggest that the paradigm for costing out the value is missing variables that actually make this a very simple sell.
>
> 
>
>1.	Cost of childhood accidental poisonings.
>2.	Cost of burglary for drugs, and teenage pharming
>3.	Cost of patient medication errors from having accumulated a
>confusing pile
>4.	Cost of environmental injury goes here*someday
>
> 
>
>But there is now a 5th: The cost of disposal in third world countries of badly donated drugs that don't meet the 1999 WHO Guidelines and that now for example have a price tag of over 1 million Euros in Banda Aceh alone for the 340 tons of unusable "donations." 
>
> 
>
>Maybe I'm overstating a bit, but those seem compelling arguments and I simply added the word cost to each for the sake of this email.
>
> 
>
>Seems actually to make it more starkly important.
>
> 
>
>Stevan Gressitt, M.D.
>
>207-441-0291  
>
> 
>
>  _____  
>
>From: Gilliam, Allen [mailto:GILLIAM at adeq.state.ar.us] 
>Sent: Tuesday, November 22, 2005 2:25 PM
>To: H2E - Hospitals for a Healthy Environment - Info Exchange Listserv
>Cc: pharmwaste at lists.dep.state.fl.us 
>Subject: [h2e] RE: any legislation/ordinances banning disposal of pharmaceuticals to sanitary sewer?
>
> 
>
>H2E -- Hospitals for A Healthy Environment Info Exchange Listserve
>(h2e at email.sparklist.com)
>
>tough questions Dan!
>
> 
>
>easy, but time and resource intensive anwer?  City Pretreatment programs and their inspectors (doubt the epa will come up with the regs).  40 cfr 403 (the national pretreatment regs which are self-implementing) apply to all "non-domestic dischargers":  
>
>§ 403.2 Objectives of general pretreatment regulations.
>
>By establishing the responsibilities of government and industry to implement National Pretreatment Standards this regulation fulfills three objectives:
>
>(a) To prevent the introduction of pollutants into POTWs [publicly owned treatment works] which will interfere with the operation of a POTW, including interference with its use or disposal of municipal sludge;  
>
>(b) To prevent the introduction of pollutants into POTWs which will pass through [cause toxicity] the treatment works or otherwise be incompatible with such works; and
>
>(c) To improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges.
>
>best management practices or general permits can and might be required, paperwork (daily procedure logs, manifests and/or bills of laden) will have to be available for review upon request by the city's inspectors that all meds/lab chems were disposed of off-site.  these cities have the authority for implementing the same type enforcement options that epa and the states do including civil and/or criminal penalties, administrative orders, severing your sewer service, imprisonment, publishing your facility's name in the local newspaper for being non-compliant, etc.  
>
> 
>
>that's why the clean water act created the program.  let the cities decide at their own discretion, what's allowed into their sewage collection systems.  who better to make the judgement than the folks protecting its publicly own assets and have a chance to interact with their next door neighbors, business leaders, civic clubs, council members, etc on a daily basis?
>
> 
>
>it's in this office's lowly opinion that a federal or state decision would side with the city.  if you get down to the Act's Pretreatment reg. bare bones, a city with a publicly owned sewer systerm is not obligated to take ANY non-domestic wastewater.
>
> 
>
>inducements/incentives?  environmental stewardhip and doing the right thing is a hard sell when there's no immediate monetary gains mentioned in the same sentence (and, as previously mentioned, no absolute proof of toxicity after it passes thru a city's w.w. treatment plant).  avoiding fines would be my reward and a plaque in the window an article in your newletters/ads that your facility is a recognized environmental friendly facility with a certified EMS (go H2E!) should help your bottom line in the long run. 
>
> 
>
>[sorry, but i've taken the liberty of cc'ing the pharmawaste listserve at the risk of violating any unknown cross talking policies as i know many of you are on both anyway.  somebody chew me out if i did bad....got my leather on today....].
>
> 
>
>alot of eyes still need to be opened and more information gained nationwide.
>
> 
>
>have a great holiday,
>
> 
>
>allen gilliam
>
>adeq state pretreatment coordinator
>
>501.682.0625  
>
> 
>
>     -----Original Message-----
>From: Dan Durett [mailto:durett at verizon.net] 
>Sent: Monday, November 07, 2005 10:16 PM
>To: H2E - Hospitals for a Healthy Environment - Info Exchange Listserv
>Cc: h2e at email.sparklist.com 
>Subject: [h2e] RE: any legislation/ordinances banning disposal of pharmaceuticals to sanitary sewer? H2E -- Hospitals for A Healthy Environment Info Exchange Listserve
>(h2e at email.sparklist.com)
>Banning the disposal of all pharmaceuticals to the sanitary sewer through an ordinance will accomplish what level of reduction?  What time frame?  How will the ordinance be implemented and monitored?  What enforcement model will be utilized (penalty of fines, impreisonmet or both?)  What inducements / incentives will be in place? Will there be awards relating to compliance? How will the ordinance be applied? Will it first be applied to university based research operations and hospitals? To private hospitals and then public ones?  Before adopting an ordinance have they looked at recent state or federal court decisions?  
>
> 
>
>Not sure these questions are helpful.  However, IF I was siting on a city council, these are just some of the many questions I would want to have
>answers to prior to voting yes on this matter.   
>
> 
>
>Dan Durett, President
>
>Dan Durett & Associates
>
>257 St. Marks Place
>
>Staten Island, NY 10301
>
> 
>
>(B) 718-876-0718
>
>(F) 718-876-7988
>
>(C) 347-563-5965
>
>durett at verizon.net 
>
>
>  _____  
>
>
>From: Barr, Marcia [mailto:barrm at upmc.edu] 
>Sent: Monday, November 07, 2005 12:59 PM
>To: H2E - Hospitals for a Healthy Environment - Info Exchange Listserv
>Subject: [h2e] RE: any legislation/ordinances banning disposal of pharmaceuticals to sanitary sewer?
>
> 
>
>H2E -- Hospitals for A Healthy Environment Info Exchange Listserve
>(h2e at email.sparklist.com)
>
>Dave,
>
> 
>
>Can you answer this?
>
> 
>
>Marcia M. Barr, BSCE 
>Division Director 
>Center for Environmental Oncology 
>Environmental Assessment, Monitoring & Control Division 
>Phone: 412.623.5783 
>Fax: 412.623.3201 
>http://www.upci.upmc.edu/ceo 
>
>-----Original Message-----
>From: Cecilia Deloach [mailto:cdeloach at hcwh.org] 
>Sent: Monday, November 07, 2005 11:53 AM
>To: H2E - Hospitals for a Healthy Environment - Info Exchange Listserv
>Subject: [h2e] any legislation/ordinances banning disposal of pharmaceuticals to sanitary sewer?
>
>H2E -- Hospitals for A Healthy Environment Info Exchange Listserve
>(h2e at email.sparklist.com)
>
>Hi all-
>
> 
>
>One of the municipalities we are working with is considering an ordinance to ban the disposal of all pharmaceuticals to the sanitary sewer. Does anyone know of any other city, municipality, state or other who has passed a similar ban? I know there is a lot of concern about pharmaceuticals in wastewater, but just trying to get a sense of what regulatory action has been taken on this area.
>
> 
>
>Many thanks in advance for your input.
>
> 
>
>Cecilia DeLoach
>
>H2E State Partnership Program Coordinator
>
>1901 N. Moore Street, Suite 509
>
>Arlington, VA 22209
>
>Ph: 800-727-4179
>
>E-mail: cecilia.deloach at h2e-online.org 
>
>www.h2e-online.org 
>
> 
>
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