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University of Washington (UW) Profile
> Three campuses, two academic medical centers, numerous clinics and offsite research facilities.
> $1.4 Billion in total grants and contracts for FY 2013– Largest research volume for public higher education
> 1.7 Million square feet of lab space and 4,000 labs
> 51,500 students> 4,300 faculty and almost 30,000 staff
– 3rd largest non-federal employer in Washington State.
Our “growing” problem of pharmaceutical waste disposal
> Dramatic increase in waste volume…
2005 2006 2007 2008 2009 2010 2011 2012 2013 20140
5000
10000
15000
20000
25000
30000
35000
40000
Quantity of Waste Pharmaceuticals
Year
tota
l disp
osed
in K
g
Our “growing” problem of pharmaceutical waste disposal, part 2
> Increased volumes at our offsite locations also
2009 2010 2011 2012 2013 20140
200
400
600
800
1000
1200 Pharmaceutical Disposal at offsite facilities
Year
Tota
l am
ount
in K
g
The issues
> Increased disposal cost (currently $2.23/kg)> Increased volume = increased workload> Training> Impact on Generator status> what to do with DEA regulated materials
– Onsite destruction issue
> Use of Washington State Pharmacy Rule?
The Process
> First step is designation– Formularies– RCRA vs State Regulated Only– DEA scheduled pharmaceuticals– Generator status– RMW
> Second step is determining best packaging options
> Third step is training in segregation and use of the various packaging options
Generator Status
> Washington State has its own Department of Ecology– They have 3 types of generators
> SQG = less than 2.2 lbs of acutely hazardous waste (AHW) or extremely
hazardous waste (EHW, specifically WT01 waste code) and less than 220lbs of dangerous waste (DW).
> • MQG –220 lbs to 2200 lbs DW.> • LQG – more than 2200 lbs DW or more than 2.2 lbs of
AHW or WT01.
Waste Profile
> At first we separated EHW and DW waste streams and Chemo
> Then worked with our vendor to combine all waste streams into one profile with variable codes
Washington State Department of Ecology
> They have 3 options for how you can handle your Pharmaceutical waste disposal.
Washington State Department of EcologyContinued…
> You can manage state only dangerous waste under the “Conditional Exclusion for Pharmaceutical Waste” (WAC 173-303-071(3)(nn))
> You can use the “Interim Enforcement Policy for Pharmaceutical Waste” (Ecology publication #07-04-024)
> Or you can just manage it like any RCRA hazardous waste
That means you have to segregate it out from the rest
But while those are some good advantages, there are disadvantages that lead us not to use this Policy. Our LQGs would still be LQGs, and amount of EHW @ SQGs = SQG
Segregation of Pharmaceuticals at SQGs
> We provide them with a short simple “cheat sheet” list of types of drugs we need to know if they will have for disposal.
Training
> We provide guidance and help in developing training materials for the various staff involved with this waste stream
> This is an example of a flow chart we made to help one location train their staff
Can you help…
> Our biggest unresolved issue is to find an onsite destruction method for our DEA regulated pharmaceuticals that our waste contract will accept.
> New Final Rule allows for “non-retrievable” drugs to be considered no longer DEA regulated.
> Do you have something that works?