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Pharmaceutical Waste Management Luring Pollution Prevention into Compliance Assistance

Pharmaceutical Waste Management Luring Pollution Prevention into Compliance Assistance. Sara Johnson, M.S. Pollution Prevention Program Environmental Summit – Providence, RI September 29, 2005. Agenda. Pollution Prevention = Compliance Assistance

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Pharmaceutical Waste Management Luring Pollution Prevention into Compliance Assistance

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  1. Pharmaceutical Waste ManagementLuring Pollution Prevention into Compliance Assistance Sara Johnson, M.S. Pollution Prevention Program Environmental Summit – Providence, RI September 29, 2005

  2. Agenda • Pollution Prevention = Compliance Assistance • Hospital’s Perspective of Managing Pharmaceutical Waste • Compliance Confusion • Regulatory Research

  3. Pollution Prevention = Compliance Assistance • Innocent transition • Waste reduction workshop (1998) • Mercury workshop (2000) • NH3E (2001) • Green cleaning • Green purchasing • Alternative technologies • Dioxin workshop (2002) • Hospitals for a Healthy Environment • Web conferences • Pharmaceutical questions • Epi pens and epi vials • Chemo waste

  4. Pharma Waste = P2 • Management of Pharmaceutical waste is NOT pollution prevention • Maybe on rare occasions • Patient care • Purchasing contracts (Group Purchasing Organizations) • Regulatory interpretation made at EPA HQs

  5. Tectonic Plates Shifted • New Hampshire’s regulatory section experienced staff reductions. • Lost knowledge and history • Can’t hold hospital’s hand • Only 26 hospitals in New Hampshire

  6. Compliance Assistance Mud Slide • NH3E Quarterly meetings • Roundtable discussions • NH DES panel discussions • List serve • H2E and NH3E • Regional EPA hospital workshop • While sponsored by P2 section, mostly compliance.

  7. Hospital’s Perspective: Pharmaceutical Waste Management • Who is managing the waste? • Environmental services • Facility manager • Pharmacist • Facility Size • Upper CT <40 beds • Dartmouth >400 beds • What are my chances at being inspected?

  8. Hospital’s Perspective: Be Specific • What color should the buckets be and where to purchase them? • Waiver for nitroglycerine? • Should I just wait for the rule change and hope for the best? • What do we do with the items that are not listed? • EPA list not current, new pharmaceuticals are more toxic

  9. Sector Specific Questions • Every scenario under the sun. • Mainly mixture questions • P-list with a U-list • P-list with another pharma • U-list with another pharma • Chemo cocktail • Spills versus splatters • Used versus unused

  10. Hospitals Are Different Aren’t They? • The dilution rate is different. • Healthcare is different from manufacturing. We should have different rules. • Epinephrine is naturally occurring substance. • Rinse the bottles and then manage the rinsate?

  11. Compliance Confusion • Waste streams are generated throughout facility • Wastes are not one “type” • Chemotherapy waste can be infectious, hazardous and/or solid waste. • Safety concerns

  12. Compliance Denial • Go to numerous workshops to try get a different answer. • “Expert” advice • Reverse distributors • Group purchasing organizations • OSHA • Healthcare corporations • Waste vendors

  13. Regulatory Research • Web page • Multiple guidance documents • FAQs – pharma waste • Very time consuming • P2 is non-regulatory • Must get approval from regulatory programs • Everyone has a say • Can’t seem to keep things simple • Worth while • Answer is now written down • Available to the public (share with others)

  14. Current Hot Topic • Reverse Distributors • Mailing everything • IV bags • “empty” vials • Received invoice of hazardous waste • No tracking or manifest • No determination at point of generation • No addition to generator status

  15. Time is Money • Since 1999, the Healthcare project has been funded through P2 grant. • 20 to 30% of my time spent on healthcare • 3 FTE = actual P2 work • Healthcare sector • Acute and specialty hospitals, home health care, eye physicians, nursing homes, and mental health clinics

  16. Future of Compliance Assistance with Healthcare Facilities • Actively pursuing self-efficiency • H2E grant with Dartmouth • NH3E meetings • Discussion through NH3E list serve • Committing to the phrase “NO MORE” or “Keep me out of this”

  17. Sara Johnson, M.S.Hew Hampshire Pollution Prevention Program Healthcare Project Coordinator603-271-6460 www.des.nh.gov/nhppp/Healthcare_P2/default.asp

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