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Pharmaceutical Waste Management Luring Pollution Prevention into Compliance Assistance Sara Johnson, M.S. Pollution Prevention Program Environmental Summit – Providence, RI September 29, 2005
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Agenda Pollution Prevention = Compliance Assistance Hospital’s Perspective of Managing Pharmaceutical Waste Compliance Confusion Regulatory Research
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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
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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
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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
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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.
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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?
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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
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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
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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?
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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
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Compliance Denial Go to numerous workshops to try get a different answer. “Expert” advice –Reverse distributors –Group purchasing organizations –OSHA –Healthcare corporations –Waste vendors
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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)
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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
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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
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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”
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Sara Johnson, M.S. Hew Hampshire Pollution Prevention Program Healthcare Project Coordinator 603-271-6460 www.des.nh.gov/nhppp/Healthcare_P2/default.asp
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