Recently, there has been a high-level of regulatory attention placed on hospitals, clinics, and medical laboratories that generate hazardous wastes. For example, in September 2004 the Nebraska Medical Hospital was cited for disposing of cyclophosphamide into yellow sharps containers and not properly managing them as a U-listed wastes. In another example, the Children’s Mercy Hospital in Kansas City, Missouri was issued a Consent Agreement and Final Order on September, 18th, 2008. The majority of these issues are fairly standard RCRA hazardous wastes management issues for general industry, but have seem to escape recognition by the medical industry. Much like the early days of potent compound safety programs, employees seem to not recognize that a drug, a pharmaceutical product can be hazardous in an occupational setting.
One area that is of significant controversy is the concept of “reverse distribution.” Reverse distribution is the practice of when a pharmacy returns an expired pharmaceutical product to the distributor for credit or replacement. Some EPA authorized states interpret that since the expired pharmaceutical was expired at the time of shipment to the distributor, then the actual generator of the “waste” is the pharmacy not the distributor. This interpretation then requires the pharmacy to manage the waste as a hazardous waste. However, there are different opions on this issue. As you could expect, most pharmacies are not set up to manage a hazardous waste management program.
Another area that is of significant challenge for the medical community is that many material safety data sheets are inadequate for pharmaceutical products and do not clearly indicate the properties necessary to determine if the drug product meets a hazardous waste characteristic or if it’s a listed waste.
The majority of these issues could be address with basic education and training on hazardous waste management with an emphasis on the pharmaceuticals that are identified on the U- and P-listed wastes. Affygility Solutions believes that this is a significant issue and as such has offered a low-cost hazardous waste management training webinar addressing this very topic. It is a recorded session so you can take it anytime and at your convenience. For more information go to http://www.affygility.com/seminars/hazwastegen.html
keywords: potent compound safety, hospital hazardous waste, hazardous medical waste