By A.J. Plunkett
Review and update policies on the disposal of pharmaceuticals to prohibit the flushing of any drugs into the sewers. Experts say that may be the best way to ensure compliance with a new EPA regulation banning the sewering of hazardous waste pharmaceuticals that goes into effect August 21.
In addition, it will help ease requirements on front-line staffers who will no longer have to keep track of what they can and can’t flush down the drain.
And it may even help you stay on the good side of federal regulators who are encouraging the no-sewering of any drug as a best practice to protect water resources.
The August 21 ban on the sewering of hazardous waste pharmaceuticals is the first deadline set out in new regulations published by the EPA in a final rule in February that overall sets up a new category, Subpart P, under the federal Resource Conservation and Recovery Act (RCRA).
The ban is the only part of the rule that goes into effect at all healthcare facilities across the United States and its territories, without exception. That’s because the EPA is declaring the ban under the authority set out by the federal Hazardous and Solid Waste Amendments (HSWA).
Other parts of the final rule, officially known as the “Management Standards for Hazardous Waste Pharmaceuticals & Amendment to the P075 Listing for Nicotine,” are under RCRA and must be approved in each state or territory that has its own RCRA-authorized program.
The sewering ban is also one of the more stringent changes outlined in the rule. And the EPA only has the authority to ban flushing of those drugs deemed to be hazardous waste, as outline under RCRA regulation, notes Wade Scheel, director of governmental affairs for Stericycle Environmental Solutions.
However, in the preamble to the final rule, the EPA “clearly makes it known” its position on sewering of all drugs, he says.
That preamble states: “We note that although our RCRA statutory authority limits us to apply the prohibition on sewering narrowly to pharmaceuticals that are RCRA hazardous wastes, EPA strongly recommends as a best management practice to not sewer any waste pharmaceutical (i.e., hazardous or non-hazardous) from any source or location.” The EPA even goes on to ask households to do the same.
The concern is that public sewer and water systems were not designed to filter out what has become very complex chemical and biological elements found in many drugs, even if they’re not technically considered hazardous waste, says Scheel.
Pharmaceuticals can have a significant impact on the environment, according to Michael Ganio, PharmD, MS, BCPS, FASHP, director, pharmacy practice and quality, with the American Society of Health-System Pharmacists (ASHP).
“Studies have shown that non hazardous-waste drugs that are disposed of down the drain can be found in water supplies and in lakes and streams, so a best practice is not to dispose of any pharmaceuticals down the drain,” says Ganio.
Because of such impacts, many of the larger health systems and healthcare facilities have abandoned the practice of sewering already, notes Scheel.
While the new federal ban may not have a major impact on those hospitals and healthcare facilities, smaller facilities, especially in rural areas, will have to ensure policies are in place to adhere to the prohibition.
The main problem will be identifying what pharmaceuticals are considered hazardous waste under RCRA and which are not, and then training staff to know the difference, says Scheel.
Having staff make those decisions while also on the frontline of providing care can be an onerous demand, he notes.
To help them, and to ensure compliance, create a “make-it-easy button” for them and prohibit the flushing of all pharmaceuticals, recommends Scheel.
Facilities that do not want to follow that recommendation will need to inventory the pharmaceuticals disposed of on site and update disposal policies to identify which are considered hazardous waste under RCRA and prohibit them from being sewered.
“The sewering ban applies to hazardous pharmaceutical waste, commonly referred to as P- and U-listed waste. The lists contain drugs that are considered toxic, reactive, corrosive, or ignitable. The lists are not updated frequently, and institutions should have systems in place to ensure the proper disposal of P- and U-listed waste,” says Ganio.
Editor’s note: A.J. Plunkett is editor of the Simplify Compliance newsletter Inside Accreditation & Quality.