The RCRA requires hazardous waste to be placed into special containers at the point of generation within the sur- gical suite. Black containers are the most commonly used color for hazard- ous waste. An organization may decide to manage all drug waste generated in surgery as hazardous waste to avoid decision-making during the procedure. Controlled substances regulated by the Drug Enforcement Administration (DEA) must be disposed of in accor- dance with DEA rules such as render- ing the substance non-retrievable and having the disposal witnessed by two health care professionals. The area where the hazardous drug
waste is generated is known as the sat- ellite accumulation area and will in- clude each surgical suite and any other areas in which drugs may be discarded. In those areas, the containers should be placed in a location convenient to the
anesthesiologist and nursing person- nel. Many hospitals have chosen to attach the containers to the anesthe- sia carts. The administrative manager of an ASC is usually responsible for managing the purchasing and deploy- ment of the containers, as well as their removal and storage in a storage accu- mulation area, while awaiting transport to a hazardous waste facility. The EPA requires the containers to be moved to the storage accumulation area within three days of being filled and sealed. If segregated, non-hazardous phar- maceutical waste can be placed in white containers. Trace chemotherapy waste should continue to be placed into yel- low containers and regulated medical waste, including sharps, into red con- tainers. Sharps should not be placed into the black containers as this creates an expensive “dual” regulated medical and hazardous waste.
Decisions should also be made re-
garding the disposal of non-P-listed packaging. For example, while the trash is legal, vials that have held controlled substances should be placed into sharps containers to prevent possible diversion. The following IV solutions can con- tinue to be sewered: dextrose, saline, sterile water, Lactated Ringer’s, K+ salts, Ca++
salts and Mg++ salts.
Attend my presentation titled “Man- aging Pharmaceutical Waste in the ASC Setting” at ASCA 2013 to learn more about how to safely, and cost-ef- fectively, dispose of your ASC’s phar- maceutical waste. For more informa- tion about ASCA 2013, go to
www.asc
association.org/asca2013.
Charlotte A. Smith is a senior regulatory adviser with WM Healthcare Solutions, PharmEcology Services of Houston, Texas,
www.pharmecology.com.
ASC FOCUS MARCH 2013
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