Pharmaceutical Waste Management A Northwest Update

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Ross Russell
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1 Pharmaceutical Waste Management A Northwest Update Dave Galvin Local Hazardous Waste Management Program in King County Seattle, WA December 9, NAHMMA

2 Intent Brief background on the issue Washington State s rule change Current work related to rule, businesses Nursing homes Household medications Incl. Clark County, WA, experience Other projects underway around U.S.

businesses Nursing homes Household medications Incl.

3 Why pharmaceutical waste is an issue Pharmaceuticals are widely used, showing up in environment Category includes medicines, drugs, some personal care products Hormones, steroids, antibiotics, analgesics, anti-depressants, chemotherapeutics, impotence drugs, preservatives, disinfectants, sunscreen agents, fragrances, etc., etc.

Hormones, steroids, antibiotics, analgesics, anti-depressants, chemotherapeutics,

4 Why pharmaceutical waste is an issue (cont d) Some pharmaceutical wastes designate as hazardous under RCRA or state laws P-listed wastes (epinephrine, nitroglycerin, warfarin) U-listed wastes (lindane, chemo agents) Ignitable (various alcohols) Corrosive (acetic acid, NaOH) Toxic (arsenic, barium, cadmium, chromium, mercury, selenium, silver)

warfarin) U-listed wastes (lindane, chemo agents) Ignitable (various alcohols)

5 Why pharmaceutical waste is an issue (cont d) Most pharmaceutical wastes are improperly disposed Few in health care know RCRA regs or follow RCRA-designated pharmaceutical wastes are estimated to be 5% of total, which equals about 4 million pounds per year in U.S. (most of which is not handled according to RCRA regs)

pharmaceutical wastes are estimated to be 5% of total, which equals about 4

6 Why pharmaceutical waste is an issue (cont d) Pharmaceuticals are also regulated by other agencies for other reasons Federal Drug Enforcement Administration Federal Food and Drug Administration State Boards of Pharmacy

7 Why pharmaceutical waste is an issue (cont d) Pharmaceuticals generally fall into 3 categories: Controlled substances Legend (prescription) drugs Over-the-counter medicines RCRA and state-desig. hazwastes are found in all three categories Destruction is required for controlled substances and illegal drugs

Over-the-counter medicines RCRA and state-desig.

8 Washington State destruction Catch 22 DEA requires controlled substances to be destroyed in DEA-permitted incinerators None of these are RCRA-permitted nor state-permitted (for state-only wastes) Some pharmaceutical wastes need to be destroyed, yet because they designate, they could not be legally destroyed in state waste-to-energy incinerators

state-permitted (for state-only wastes) Some pharmaceutical wastes need to be

9 Washington State resolution State amended its hazardous waste rules to exclude pharmaceutical wastes from hazwaste designation if they are destroyed in incinerators that meet certain conditions Washington Administrative Code (3) (nn) (ii). Examples of wastes affected Aborted doses, illegal drugs seized by lawenforcement, expired medicines, samples

that meet certain conditions Washington Administrative Code 173-071 (3) (nn) (ii).

10 Current work in WA related to rule Law enforcement storage backlogs dealt with DEA enforcements due to lack of timely destruction of certain wastes reduced Dept. of Ecology and King County still trying to get the word out to hospitals, clinics, law enforcement, pharmacies I.D. vendors who can ship

11 Nursing Homes Current regulatory conflict being looked into in WA: For pharmaceuticals, Ecology views nursing homes as residential and applies household exemption for drug wastes State Board of Pharmacy and DSHS view nursing homes more like hospitals Key issue: who controls the drugs and their wastes, the patients or the nursing home?

exemption for drug wastes State Board of Pharmacy and DSHS view nursing homes more

12 Household pharmaceutical wastes What is the best way for these wastes to be handled? WA has a workgroup looking at different models: HHW collection services Pharmacy take-back coupled with reversedistributors Pre-paid mailers Mandatory product stewardship system

WA has a workgroup looking at different models: HHW collection

13 Clark County WA experience Controlled substances go to Sheriff s Office (to be handled and disposed with no-longer-needed evidence) HHW collection sites take all household drug wastes Small network of pharmacies has agreed to take household drug wastes, with Co. HHW services picking up for handling Jim Mansfield x4016

household drug wastes Small network of pharmacies has agreed to take household

14 Other U.S. examples 2 EPA pilot grants Household prescription medication waste (MA, NE Recycling Council) 1-day pilot collection set for Dec. 9 th Hospital pharmaceutical wastes (NH) I.D. best management practices California determination 11/30/04 that household pharmaceutical wastes are not HHW (allows for collection at nonpermitted locations such as pharmacies)

15 Where to from here? Need a national workgroup i.d. who is interested in this topic Share experiences, keep up-to-date Discuss options Develop national product stewardship recommendations Avoid simply adding these wastes to HHW and CESQG services

16 Contact: Dave Galvin Local Hazardous Waste Management Program in King County 130 Nickerson Street Seattle, WA

Managing Pharmaceutical Wastes: Law and Regulations

Managing Pharmaceutical Wastes: Law and Regulations James T. Price Missouri Waste Control Coalition Conference June 30, 2014 2014 WA 5625923.1 From the Missouri Department of Natural Resources Health Care: