Management of Pharmaceutical and Hazardous Waste from the University of Illinois at Chicago Medical Center

1. Management of Pharmaceutical and Hazardous Waste from the University of Illinois at Chicago Medical Center Presenter: Gregory H. Gehrig Environmental Compliance Specialist UIC Environmental Health and Safety Office

2. Presentation Overview Topic importance. Introduce UIC and UIC Medical Center; Definitions, including a hazardous waste overview. Generation and management of pharmaceutical waste, in general and at UIC Medical Center. Mention that I will touch on the definition and handling of Mention that I will touch on the definition and handling of

3. Presentation Overview (Cont.) Focus in on the generation and management of pharmaceutical hazardous waste, both in general and at the UIC Medical Center. Challenges managing certain waste streams. Questions and discussion.

4. Sources of Information Managing Pharmaceutical Waste: A 10-Step Blueprint for Health Care Facilities in the United States; Hospitals for a Health Environment; April 15, 2006. RCRA Orientation Manual; US EPA, January 2003. Applicable regulations. UIC EHSO and Medical Center.

5. Importance Regulatory agencies oversee the proper management of pharmaceutical waste, including: US EPA; DEA; DOT; Joint Commission for Accreditation of Healthcare Organizations (JCAHO). Fines and other penalties for non-compliance. Liability for improper waste disposal.

6. Recent Regulatory Action Increased regulatory scrutiny by US EPA. Region 2 (inc. NY, NJ) has conducted aggressive inspection and enforcement in hospitals. Penalties range between $40,000 to $280,000. VA was required to install $500,000 waste management system and pay approx. $50,000 penalty.

7. Formed in 1982 Consolidation of University of Illinois Medical Center and University of Illinois at Chicago Circle. Medical Center dates back to the mid-1800s. Over 25,000 students. Over 11,000 employees. More than 100 buildings on 250 acres Additional sites in Rockford and Peoria.

9. UIC Medical Center Located about two miles southwest of Chicago Loop. 500 Bed, 8 Story hospital and outpatient center. Largest teaching hospital in the US. 24-hour ER with over 53,000 visits. �Care of Last Resort� for residents of Illinois.

10. Definitions Pharmaceutical waste � A mix of hazardous waste, non-hazardous waste, controlled substances and regulated medical waste (RMW) which are sometimes difficult to differentiate and segregate. Controlled Substance � Narcotics, depressants and stimulants manufactured for legitimate medical purposes with the potential for abuse. Regulated Medical Waste (RMW) � bodily fluids, other infectious or potentially infectious materials, and associated debris (sharps, PPE, etc.).

11. Review of Hazardous Waste A substance defined as hazardous waste per RCRA in 40 CFR Part 261 Subpart D. Characteristic Wastes � Wastes that exhibit toxic, corrosive flammable, or reactive hazardous characteristics. Listed Wastes � Wastes that are defined as hazardous by the regulation. Generator must ensure proper ID, segregation, transportation and disposal of hazardous waste (Cradle to Grave).

12. Listed Hazardous Wastes F � Common industrial and manufacturing processes. K � Specific industries, sources and processes. Both P and U include pure or commercial grade unused materials. P � acutely toxic. U � toxic plus other hazardous characteristics.

13. 2 Conditions That Make a P or U listed Chemical a Hazardous Waste Sole Active Ingredient. NOT used for intended purpose.

14. Empty Containers Empty containers of D, F, K, and U listed wastes are not considered hazardous waste. Empty containers of P-listed wastes are considered hazardous waste. Empty containers must be triple rinsed (with the rinsate collected as hazardous waste). Note that if the contaminated debris is grossly impacted it would be considered hazardousNote that if the contaminated debris is grossly impacted it would be considered hazardous

15. P and U Listed Debris Considered hazardous waste. Spills. Impacted PPE.

16. Hazardous Waste Identification With well defined processes (i.e. pathology and laboratories), this is not a problem. More difficult with pharmaceuticals that are also hazardous wastes. Busy staff (e.g. nurses, pharmacists, etc.) may hinder ability to educate.

17. Hazardous Waste Generation at the UIC Medical Center Pathology � Formalin, xylene. Hospital Wide � Mercury-containing devices, including thermometers and blood pressure gauges. Oncology � Select chemotherapy agents (but not all). Pharmacy � Select discarded pharmaceuticals. Laboratories � Specialty chemicals (typically generated during cleanouts).

18. Waste Segregation and Collection Segregation of large volumes of hazardous waste (i.e. xylene) is easier at the point of generation. Pharmaceuticals are more difficult, especially empty containers of P-listed wastes. Once a material is identified as a waste, then a segregation and collection program can be implemented. Busy staff = try to minimize labor intensive or time-consuming programs.

19. Pharmaceutical Hazardous Waste Segregation Easier in the pharmacy. More difficult in patient care areas. Work with central pharmacy as they control drugs from �beginning to end�.

21. Common P-Listed Epinephrine � IV solutions and syringes on crash carts. Warfarin � Pills. Nicotine � Patches and gum.

22. Common U-Listed Cyclophosphamide � Antineoplastic (chemo agent), IV solution. Daunomycin �chemo agent, IV solution. Melphalan �chemo agent, IV solution or tablet. Selenium � IV solution. Selenium Sulfide � 2.5% lotion.

23. Collection Strategy Provide a location where hazardous waste pharmaceuticals can be placed for collection within easy reach of where most generation occurs.

24. Collection Points Central Pharmacy. Operating Room. Satellite pharmacies on floors where epinephrine is dispensed (6th and 7th floors). Nursing stations where epinephrine is dispensed.

25. UIC Interpretations Regarding Select Waste Streams These are based on: US EPA and other agency interpretations. In the absence of clear interpretation, then liability vs. operational difficulty is considered.

26. Not Considered Hazardous Waste: Used nicotine patches and patch backings. Used epinephrine syringes (but not IV bags). Nitroglycerin/pharmaceutical compounds that aren�t explosive. Any pharmaceutical or container returned to the distributor, manufacturer or sent to DEA as a controlled substance. Used souffl� cups.

27. Drain Disposal Explicitly accepted by a publicly-owned treatment works (POTW). Must notify POTW if dumping P-listed wastes, or more than 33 lbs/month of U-listed and characteristic wastes. No dilution (important with characteristic wastes).

28. Management of Regulated Medical Waste (RMW) Pharmaceuticals Often should not be landfilled. Returned to distributor or manufacturer. Incinerated as a Best Management Practice (BMP).

29. Other Waste Scenarios Infectious RMW + hazardous waste. Radioactive waste + hazardous waste. Infectious RMW + hazardous waste + radioactive waste.

31. Costs Incineration of pharmaceutical hazardous waste is 10 to 20 times more expensive than incineration of RMW. Incineration of pharmaceutical hazardous waste will cost approximately $5,000/yr more than if incineration as RMW.

32. Questions? Comments?