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Managing Pharmaceutical Waste in Washington State

Managing Pharmaceutical Waste in Washington State. Chad Fisher Hazardous waste Compliance Inspector Wa state department of ecology August 30, 2013. Overview for Today. • Dangerous waste management overview • Options for managing pharmaceutical waste

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Managing Pharmaceutical Waste in Washington State

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  1. Managing Pharmaceutical Waste in Washington State Chad Fisher Hazardous waste Compliance Inspector Wa state department of ecology August 30, 2013

  2. Overview for Today • Dangerous waste management overview • Options for managing pharmaceutical waste • History of Ecology’s work on pharmaceutical waste • Challenges (violations) we’re seeing with generators of pharmaceutical waste during dangerous waste inspections

  3. Dangerous Waste Management Overview • Must designate waste • WAC 173-303-070 through -100, -170 • Notification – based on generator status • WAC 173-303-060, -170, -070(8) • Annual reporting – based on generator status • WAC 173-303-220, -390, -070(8) • On-site management – based on generator status • WAC 173-303-200, -201,-202, -320, -630, -640, -070(8) • Manifest waste – based on generator status • WAC 173-303-180, -070(8) • Guide for Dangerous Waste Generators in WA State – Pub#98-1252

  4. Options for Managing Pharmaceutical Waste Dangerous Waste Regulations Interim Enforcement Policy (IEP) • Chapter 173-303 WAC • Conditional exclusion • WAC 173-303-071(3)(nn) • Enforcement discretion policy • Publication # 07-04-025 • Conditional exclusion • WAC 173-303-071(3)(nn) • www.ecy.wa.gov/programs/hwtr/pharmaceuticals/index.html

  5. Pharmaceutical Waste Management Dangerous Waste Regulations Interim Enforcement Policy • Must designate pharmaceutical waste • Must count & report all DW pharmaceutical waste • Counts towards generator status • TurboWaste reporting based on facility generator status • May utilize conditional exclusion • Must designate pharmaceutical waste • No count or report for pharmaceutical waste • Does not count towards generator status • Must submit profile and notification • TurboWaste reporting continues for remainder of facility • May utilize conditional exclusion

  6. History: Ecology’s work on pharmaceutical waste • Memorandum Of Understanding with WA State Hospital Association in 2005: technical assistance focus • Generator inspections including pharmaceutical waste began in approximately 2011 • Ecology continues to work with both generators and transporters of pharmaceutical waste: both compliance inspections and technical assistance

  7. Recent inspection findings: general principles • Training • On site contact and/or staff not familiar with pharmaceutical waste program • Improper segregation of dangerous waste pharmaceuticals • Non-empty vials/syringes disposed in sharps, Regulated Medical Waste, or garbage containers • Container management • Labeling and/or accumulation requirements not met • If using IEP, notification and profile not submitted to Ecology • Without notification, the Policy’s enforcement discretion not possible

  8. Recent compliance inspection findings: specifics Scope: Within Ecology’s Northwest Region (King, Snohomish, Skagit, Whatcom, Kitsap and Island Counties), September 2011 to present. # of visits: 18 # of inspections: 17 # of technical assistance visits: 1 Of total facilities, # using IEP: 11 Of total facilities, # not using IEP: 6

  9. Recent compliance inspection findings: specifics • Improper segregation of dangerous waste pharmaceuticals: non-empty vials/syringes disposed in sharps, regulated medical waste, or garbage containers (improper disposal) # of visits resulting in a violation: 10 # of visits resulting in a “concern”: 5 # of visits resulting in no violation or “concern”: 3 New publication: “Focus On Dangerous Waste: Handle Pharmaceutical Waste Properly” https://fortress.wa.gov/ecy/publications/SummaryPages/1304013.html

  10. Example: pharmaceutical waste in garbage

  11. Example: pharmaceutical waste in sharps

  12. Example: pharmaceutical waste in sharps

  13. Example: pharmaceutical waste in sharps

  14. Recent compliance inspection findings: specifics • Container management: labeling and/or accumulation requirements not met • Examples: hazardous waste/dangerous waste label, risk label, accumulation start date (if applicable), closed container # of visits resulting in a violation: 15 # of visits resulting in a “concern”: 1 # of visits resulting in no violation or “concern”: 2 • In both cases there were other problems with managing pharmaceutical waste

  15. Context: Current and Future • Ecology understands that pharmaceutical waste management is a significant challenge for healthcare facilities. • Ecology expects generators to continue to move forward with implementation of a compliant pharmaceutical waste management program. • In addition to regular compliance inspections, Ecology provides: • technical assistance through the compliance program • technical assistance through the Pollution Prevention Planning Program • The Interim Enforcement Policy for Pharmaceutical Waste is still … an interim policy. Changes in WA State pharmaceutical waste regulations are not likely until after EPA’s rule is final. • EPA is planning to have a draft pharmaceutical waste rule in 2014.

  16. Pharmaceutical Waste Management Northwest Region • Technical assistance • Jenny Yoo • 425.649.7166 • jyoo461@ecy.wa.gov • Compliance assistance • Chad Fisher • 425.649.7281 • cfis461@ecy.wa.gov • Trudy Harding • 425.649.7289 • thar461@ecy.wa.gov Central Region • Technical assistance • Holly Cushman • 509.575.2724 • hcus461@ecy.wa.gov • Compliance assistance • Amy Cook • 509.575.2477 • acoo461@ecy.wa.gov Southwest Region • Technical assistance • LeattaDahlhoff • 360.407.6339 • leda461@ecy.wa.gov • Compliance assistance • Lisa Perle • 360.407.7553 • lper461@ecy.wa.gov Eastern Region • Compliance assistance • Lori Rodriguez • 509.329.3449 • lrod461@ecy.wa.gov Statewide Questions – Ecology HQ • Tom Cusack • 360.407.6755 • tcus461@ecy.wa.gov

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