Pharmaceutical Waste Management Program
University of Chicago Medical Center
Introduction
• University of Chicago Medical Center (UCMC) will be implementing a program to collect Pharmaceutical (Rx) waste throughout the hospital.– The program has been designed to collect and manage
this waste using Best Management Procedures.
• Training Module:– This training module is designed to explain the
requirements, describe the identification process, and show how pharmaceuticals will be identified by the Pharmacy and collected in various containers in all departments of the hospital.
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• Program Overview– Pharmacy evaluates the hospital formulary and develops
a quick and easy way (through identifiers) to indicate where to place the waste.
– Staff administers the Pharmaceutical and looks for the identifier(s) to determine where to dispose of waste.
– Staff disposes of the Pharmaceutical waste in containers placed strategically in their Unit.
– Staff will be required to know where to dispose of each type of Pharmaceutical waste.
– Staff will not be required to memorize what to do with each Pharmaceutical waste.
– Stericycle (third party) staff will be responsible for Pharmaceutical waste container service and transport.
Introduction
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• If there are any questions regarding this new program, please see the educational postings in each unit or contact the following individuals:– Jennifer Palombizio, Manager of Safety Office
and Environmental Compliance, 2-3363, 5-SAFE or [email protected]
– Judd Johnson, Assoc. Dir – FD&C, 2-8259 or [email protected]
– If the above individuals are not available, the Pharmacy Director can be contacted
Who to Contact With Questions
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Regulatory Environment• In addition to promoting Environmental Stewardship, there are
regulations that apply to the management and disposal of pharmaceutical wastes
• What are healthcare facilities required to do?– Manage all identified Hazardous Waste generated within the
facility (Pharmaceuticals, Lab Wastes, Engineering, Solvents, etc.). This program concentrates on the Pharmaceutical Wastes
– Some Pharmaceuticals are considered hazardous to the Environment and therefore UCMC will manage accordingly
– Rules and Regulations (EPA, IL EPA, DOT, The Joint Commission)• Federal: US Environmental Protection Agency
– Rules developed in 1976, recently began looking at Healthcare
• State: Illinois Environmental Protection Agency• Additional Regulations – Department of Transportation (when
shipping), Sewered Waste (drain disposal), The Joint Commission – Environment of Care
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Rx waste is currently being disposed of in a variety of non-compliant ways. The table below shows some common locations where Rx waste is being disposed, what can continue to go into those containers, and what cannot.
Current Rx Waste Practices
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Rx Waste Currently Disposed of In: What Will Continue to be Disposed into Existing Container
What Will no Longer be Disposed of into Existing Container
Bio-Hazardous/Red Bag Infectious waste, gauze w/ infectious material (may contain some Rx)
IVs, vials, oral meds, wrappers, inhalers that are NOT infectious
Sharps Container Syringes and sharps Full, partial and empty Rx vials , oral meds, wrappers, inhalers
Regular Trash Garbage, outside packaging, package inserts, over wrap
Full, partial and empty Rx vials and IVs, oral meds, wrappers, inhalers, creams
Drain/Sewer Controlled substances, maintenance IV solutions, basins of irrigation solutions from ORs
Full, partial and empty Rx IVs, oral meds (except controlled substances), antibiotics
Yellow Chemo Container Empty Chemo vials and IVs, empty syringes, non-contaminated gloves & gowns
Full or partial Chemo containers (vials and IVs), Chemo spills, contaminated gloves & gowns
• Controlled Substances Handling– Still must witness and waste to drain per DEA guidance and
written procedures
• Radioactive Rx and Nuclear Medicine Procedures– Follow existing procedures with half life decay, etc.
• Regulated Medical Waste– Sharps (needles, etc.) = Sharps Container– Red bag wastes = Red Bag/Infectious Waste Container
• IV Draining– Can still cut and drain non-pharmaceuticals to the drain and
bags to the garbage• Maintenance IVs and Fluids (saline, potassium, sodium chloride, D5W,
etc.)
– If Pharmaceutical is added, then manage as it is identified
Processes Not Changing
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Examples of Rx Waste To Collect
• Vials • IVs and tubing
– Doesn’t Include Maintenance IVs (Saline, LRs, Dextrose, KCl, Na Bicarb)
• Oral Medications• Partial syringes
• Unit dose packaging– Specifically - Coumadin unit dose
packaging, nicotine patch and backing
• Patient prescriptions– Left from patients and families
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The rules apply not only to the Rx in various forms and doses, but also applies to some containers that held the Rx. Examples of items to collect:
• Rx can be either Hazardous or Non-hazardous to the Environment (different from OSHA Hazardous or Bio-Hazardous definitions)
• Hazardous Rx Waste – About 6% of formulary– Rx might be identified as hazardous to the environment because
it is specifically listed (Warfarin, Nicotine)– Some Rx is hazardous because the Rx has something in it
• Rx with Alcohol is Ignitable; Some Rx are Corrosive• Some Rx contain preservatives (Thimerisol) that make them
hazardous
• Non-Hazardous Rx Waste – About 93% of the formulary– Most Rx are not hazardous according to EPA definitions but many
of these Rx may still adversely affect the environment • As a best management practice, UCMC will also collect all non-
hazardous Rx and dispose through incineration
Categories of Rx Waste
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Identifying Rx Waste Streams
• How to Identify Pharmaceuticals:– A Formulary Analysis has been completed by the
Pharmacy to identify what Rx need to be managed in which container
– Pharmacy will Identify the Hazardous Rx for disposal in Black containers
• AcuDose or EPIC MAR notification for those that are distributed through the AcuDose System
– “Dispose in Black Container”– “For Disposal Return to Pharmacy”
• Rx that has no AcuDose or MAR message or label, is Non-Hazardous and is disposed of in the BLUE Container
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WHAT ARE THE DIFFERENT TYPES OF RX WASTE?
Sewerable WastesCompatible Hazardous Waste Incompatible Hazardous Waste (Separate)Chemotherapy WastesNon-Hazardous Waste
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Items that can be cut and poured down the drain
•Plain IV Solutions•Solutions containing additives, such as:
Potassium chloride
Potassium phosphate
Sodium phosphate
Calcium Sodium
bicarbonate
•Controlled Substances
Place into a BAGGIE and RETURN TO PHARMACY
Place into BLACK
CONTAINER
Place into BLACK
CONTAINER
Place into YELLOW
CONTAINER
Place into BLUE CONTAINER
Incompatible Rx Wastes Require Segregation to Meet DOT, Safety & Disposal Requirements
Place in zip lock bag
Aerosols Inhalers with
canister
Oxidizers (Examples) Unused Silver
Nitrate
Corrosives (Examples)L-cysteine (in pediatric TPN)
Corrosives (Examples) Botox
Items identified with a message or black dot
Examples Insulin Some VaccinesTrace elements Coumadin Nicotine
Miscellaneous Rx Spill Cleanup
Debris Rx in Syringe –
Discharge into gauze, gauze in container, syringe to SHARPS
Chemotherapy Rx and containers that are NOT empty
Chemo AgentsIVs with Residual Chemo AgentsChemo Spill Cleanup DebrisVials with Residual Chemo AgentsTablets, caps etc.
Chemotherapy Rx and containers that ARE empty
Empty SyringesGowns with chemo small amount of contaminationGlovesGogglesWipesEmpty IVs / Tubing Vials
Not Labeled or Identified as Non-Hazardous Rx by Pharmacy
Examples
•Antibiotics•Lidocaine•Marcaine•Heparin
Miscellaneous• Full/partially filled
syringe – expel into gauze, gauze in container, empty syringe in SHARPS
Call EVS for PURPLE
CONTAINER
A Combination of Infectious Waste & Hazardous Rx Waste
ExamplesMust meet by the Hazardous and Infectious Waste Definitions
Managed like a spill response
Pharmaceutical Waste Stream ManagementPharmaceutical Waste Stream Management
Labeled or Identified as Hazardous / Incompatible Rx by Pharmacy
Hazardous Rx Waste
“Place in BLACK Container”
Non-Hazardous Rx Waste
No Messaging
Bulk & Trace Chemotherapy Rx Waste
Potentially Infectious & Hazardous Rx Waste
“Return to Pharmacy”
Sewer SystemSewer System
Cut and Discharge to
Drain
SHARPS NeedlesEmpty syringes (See Above)Empty controlled substance containers
SHARPS NeedlesEmpty syringes (See Above)Empty controlled substance containers
REGULAR TRASHOutside packaging and overwrap that did not contact RxRegular TrashShipping packaging
REGULAR TRASHOutside packaging and overwrap that did not contact RxRegular TrashShipping packaging
Incompatible Rx Waste
“Return to Pharmacy”
SEWERABLE WASTES
Plain IV SolutionsControlled Substances
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Items that can be cut and poured down the drain
•Plain IV Solutions•Solutions containing additives, such as:
Potassium chloride
Potassium phosphate
Sodium phosphate
CalciumSodium
bicarbonate
•Controlled Substances
Sewer SystemSewer System
Cut and Discharge to
Drain
Plain IV Solutions
• Plain IV Solutions are those prepackaged items that did not have Rx added to it
• Continue to drain Plain IV Solutions to the drain and the bags then go to the Garbage
• These Plain IV Solutions Include: Saline Lactated Ringers Potassium chloride Potassium phosphate Sodium phosphate Calcium Sodium bicarbonate
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Controlled Substances
• Continue to follow DEA witness/waste requirements per your Hospital’s Policy
• Witness and waste to the drain, sink, toilet• Do NOT dispose controlled substances:
– In RMW containers– In Hazardous Rx waste containers– In Non-hazardous Rx waste containers, or– In Trash
• Once empty, the containers can be placed into the Sharps container or Blue Non-hazardous Rx waste container
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COMPATIBLE HAZARDOUS RX WASTES
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Items identified with a message or black dotExamplesInsulinSome VaccinesTrace elementsCoumadinNicotine
MiscellaneousRx Spill Cleanup Debris
Rx in Syringe – Discharge into gauze, gauze in container, syringe to SHARPS
Place into BLACK CONTAINER
Hazardous Rx Waste
“Place in BLACK Container”
Compatible Hazardous Rx Waste
• Identified with the AcuDose message or MAR message in the Label Comments, and/or on the label
• The Rx and containers having contact with Rx (vials, IVs & Tubing, etc.) placed into container (full, partials or empty)
– Specifically includes Coumadin and Nicotine Waste and Packaging
• Place in BLACK Container
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“Place in BLACK Container”
INCOMPATIBLE HAZARDOUSRX WASTES
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Incompatible Rx Wastes Require Segregation to Meet DOT, Safety & Disposal Requirements
Place in zip lock bagAerosolsInhalers with canister
Oxidizers (Examples)Unused Silver Nitrate
Corrosives (Examples)L-cysteine (in pediatric TPN) Corrosives (Examples) Botox
Place into a BAGGIE and RETURN TO PHARMACY
Incompatible Rx Waste
“For Disposal Return to
Pharmacy”
Incompatible Hazardous Rx Waste
• Identified with the AcuDose message or MAR message in the Label Comments, and/or on the label
• Rx Waste that cannot be collected in the same container due to EPA and DOT regulations– Examples: Aerosols (mouthpiece removed), Corrosives (Robinul),
Oxidizers (unused silver nitrate sticks), Toxins (Botox)– Bag and place in Incompatible Container
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Place in Baggie
“For Disposal Return to Pharmacy ”
CHEMOTHERAPY WASTE
Bulk Chemotherapy Waste (Black)Trace Chemotherapy Waste (Yellow)
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A Chemotherapy Rx and containers that are NOT empty
Chemo AgentsIVs with Residual Chemo Agents
Chemo Spill Cleanup Debris
Vials with Residual Chemo Agents
Tablets, caps etc
Place into BLACK CONTAINER
Chemotherapy Rx and containers that ARE empty
Empty SyringesGowns with chemo small amount of contamination
GlovesGogglesWipesEmpty IVs / Tubing
Empty Vials
Bulk & Trace Chemotherapy Rx Waste
Place into YELLOW CONTAINER
TRACE Chemotherapy
• “Trace” Chemotherapy Waste is any EMPTY Chemotherapy Container (YELLOW)– Empty IVs and tubing – Syringes– Non-contaminated PPE
• Gowns, Goggles, Gloves• Wipes
– Place these items into the YELLOW Container that is currently being used
• Yellow Containers will be located on units that consistently use Chemotherapy items
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BULK Chemotherapy
• “Bulk” Chemotherapy Waste is any chemotherapy Rx that is NOT empty– Non-empty containers holding free liquid (vial, IV
bag, tubing)• Oral medications – Patient refused, medication
dropped, etc.• Discontinued Rx – Patient reaction, partial IV
– Overtly contaminated garments and spill clean up material
• Gowns, Goggles, Gloves• Spill cleanup (Rags, Wipes, Towels)
– Place into BLACK Container22
NON-HAZARDOUS RX WASTE
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Not Labeled or Identified as Non-Hazardous Rx by Pharmacy
Collect Full and Partially Full Rx Containers
Examples•Antibiotics•Lidocaine•Marcaine•HeparinMiscellaneous
Place into BLUE CONTAINER
Non-Hazardous Rx Waste
No Messaging
Non-Hazardous Rx Waste
• Identified with the AcuDose message or MAR message in the Label Comments, and/or on the label
• Managed by placing waste into BLUE Container– Majority of Rx will be Non-hazardous - therefore
no label
NO LABEL or
IDENTIFIER24
Regular Trash
• Items that can be disposed of in the regular Trash include:– Outside packaging and package inserts– Cardboard– Plain IVs and Tubing
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GENERAL REQUIREMENTS
Containers – Closed and LabeledMovement of Full ContainersSpill Response
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Container Requirements
• The hazardous waste containers (Black) must be stored in a closed and labeled– Close the containers when
not using them– The label must have at least
the words “Hazardous Waste”, a description of the contents, and the date that the container was filled (completed by Stericycle)
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PHARMACEUTICAL HAZARDOUS WASTE START DATE _____________________________
CONTAINER FULL DATE ___________________
PHARMACEUTICAL HAZARDOUS WASTE START DATE _____________________________
CONTAINER FULL DATE ___________________
• Rx Waste Containers must be under the control of the staff; therefore they will be generally located in centralized areas in each unit such as the Soiled Utility Rooms or in or near Med Rooms or Procedure Rooms
• The full containers will be managed like the Sharps Containers and picked up by Stericycle Technician
Movement of Containers
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Spill Response
• Refer to facility Spill Response Policy, which includes the following:– Call Spill Team– Secure Area– Identify Material & get MSDS– Contain and Clean-up as directed by Spill
Team• Spill Kits, Absorbents
– Dispose of Hazardous Clean-up Materials Properly
• Hazardous Waste Container29