drugs in the drinking water of at least 46


million Americans (http://hosted.


ap.org/specials/interactives/_national/ pharmawater_update/index.html).


The Waste Land


The EPA is cracking down on incorrect methods of disposal of pharmaceutical waste. Come to ASCA 2013 to learn how to discard drugs in a cost-effective and compliant manner. BY CHARLOTTE A. SMITH


Managing pharmaceutical waste in the surgical suite in compliance with all of the regulatory policies that apply is a complex


challenge. All of the stakeholders with- in an organization must work together to ensure a successful program. My presentation at ASCA 2013 in


Boston, April 17–20, will provide meth- ods that ASCs can use to dispose of phar- maceutical waste in accordance with the Resource Conservation and Recovery Act (RCRA)—the national standards for managing hazardous chemical waste in the US.


Assessing the Risk Health care facilities, such as hospitals and ASCs, retail pharmacies, veterinary clinics and physician practices often dis- pose of pharmaceutical waste by flushing it down the drain, according to interviews


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conducted by the US Environmental Pro- tection Agency (EPA) Office of Water in 2009. As a result of these unsafe disposal practices and others, pharmaceuticals have been found in surface waters and in the drinking water of major metropolitan cities. Some of the earliest findings on the hazards of unsafe disposal practices were contained in the US Geological Survey report “Water-Quality Data for Pharmaceuticals, Hormones, and Other Organic Wastewater Contaminants in U.S. Streams, 1999–2000” (http://toxics. usgs.gov/pubs/OFR-02-94/index.html). That report analyzed 139 streams in 30 states for 95 different organic wastewa- ter contaminants (OWC). Eighty-two of the 95 OWCs were detected in at least one sample; one or more were found in 80 percent of stream samples; and more than 20 were found in 13 percent of sites. In 2008, the Associated Press conduct- ed extensive studies and documented


The Federal Response Reacting to these concerns, the EPA and state environmental protection agencies are increasing their enforcement of the RCRA. Under the act, approximately 5 percent of pharmaceuticals become haz- ardous waste when the decision is made to discard them. Compliant management requires a rigorous segregation, trans- port, treatment and reporting system. Corporate fines of up to $37,500 per vio- lation, per day, per location can be levied, and no statutes of limitations apply.


Snapshot of What ASCs Need to Know Drugs that become hazardous waste un- der RCRA include P-listed chemicals, such as Physostigmine Salicylate, U-list- ed chemicals such as Mitomycin C, and chemicals with characteristics of hazard- ous waste such as ignitability and toxic- ity, which are identified with “D” codes. P-listed chemicals are considered


acutely hazardous. They are also the most highly regulated chemicals and impact the hazardous waste generator status of an organization significantly. In addition, the containers that held these drugs, such as an ampule that once con- tained Physostigmine Salicylate, must also be disposed of as hazardous waste, even when empty. U-listed chemicals are considered toxic, but their containers may be disposed of as usual when empty. The “D” codes refer to formulations that have high alcohol content (more than 24 percent), are pressurized aerosols or meet specific toxicity limits. For ex- ample, multi-dose flu vaccine contains a mercury preservative and human insulin contains m-Cresol as a preservative, both of which cause these drugs to become a hazardous waste upon disposal.


The advice and opinions expressed in this article are those of the author and do not represent official Ambulatory Surgery Center Association policy or opinion. ASC FOCUS MARCH 2013


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