Creating a Strategy for Managing Pharmaceutical Waste

Four Steps to Effective Pharmaceutical Waste Management

To safeguard patients, providers and the surrounding environment — and comply with the law — health care organizations must have a robust program for managing pharmaceutical waste. However, the process of creating and sustaining one can be overwhelming, especially if you don’t know where to start. The following are four best practices organizations can leverage to support a compliant, consistent and reliable medication waste program.

1. Identify Whether Your Waste Falls Under RCRA Regulations

Walking through your facility and assessing the types of drug waste will shape the parameters of your waste management program. First, determine whether your drug waste is RCRA hazardous or non-RCRA hazardous:

RCRA hazardous waste is governed by the Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act (RCRA) and includes chemicals deemed dangerous to the environment if not properly disposed.
Non-RCRA hazardous waste includes those materials that fall outside of RCRA regulations.

2. Characterize Your RCRA Hazardous Waste

Digging a little deeper, health care organizations must characterize the types of waste within the RCRA hazardous category, including:

P-list waste: unused chemicals that are considered hazardous
U-list waste: unused chemicals that are considered toxic
Characteristic waste: items that are ignitable, corrosive, reactive, and/or toxic

It’s important to note that controlled substance waste, which has likelihood to be abused or cause dependence, is governed by the Drug Enforcement Agency (DEA). However, these types of drugs are currently considered hazardous and are managed as RCRA waste.

To be sure you appropriately identify the different hazardous waste types, it can be helpful to consult a waste management expert like Stericycle during the characterization process.

3. Segregate Waste Based on Characterization

Once you’ve determined what you have, the next step is to figure out how and where to dispose of the different materials based on their characterization. You should segregate the various waste types, be aware of what cannot be disposed together, and have specific processes and procedures in place that address each specific type.

4. Consider All Regulations

While the EPA plays a significant role in regulating pharmaceutical waste, it is not the only agency governing this activity. Other regulating bodies, including the DEA, Department of Transportation (DOT) and Occupational Safety and Health Administration (OSHA) also have standards that mandate the proper disposal of various types of pharmaceutical waste. Understanding these requirements, in addition to state regulatory rules, is critical for consistent and comprehensive compliance.

By partnering with an expert like Stericycle that has deep experience in all the regulations and ensures you develop the correct procedures, you can be confident your organization doesn’t overlook a critical area of pharmaceutical waste compliance. For other insights, read our White Paper on pharmaceutical waste management.