Operations Related to Waste Management

Operations Related to Waste Management / en Tue, 22 Oct 2024 20:27:51 -0500 Fri, 20 May 22 11:42:44 -0500 Red, Yellow, Black, Blue: Which Waste Container Should You Use? A Guide to Waste Segregation in Healthcare /education-events/red-yellow-black-blue-which-waste-container-should-you-use-guide-waste In this webinar, Cara Simaga will explain what waste segregation is. She will also review proper disposal techniques and discuss which containers are designated for certain types of waste. Product Code: 324WBSP0622 <h4>Registration Information</h4> This is a pre-recorded, on-demand webinar available at your convenience. On the webinar release date, you will receive an email with a link to the webinar. This webinar will remain available on-demand following the initial release date. <hr /> Speakers: Cara Simaga Director of Regulatory Affairs Stericycle Fri, 20 May 2022 11:42:44 -0500 Operations Related to Waste Management Pharmaceutical Waste Update Webinar: Save Money, Reduce Risk with Subpart P /education-events/pharmaceutical-waste-update-webinar-save-money-reduce-risk-subpart-p <h3>12:00pm CST. To be&nbsp;available after initial broadcast on demand.</h3> Join us Wednesday, April 21, 2021 for a live presentation describing EPA’s new Subpart P Hazardous Waste Pharmaceuticals Rule and how it can simplify pharmaceutical waste management in your organization while saving money in training, handling, and disposal requirements. We’ll discuss the OTC nicotine exemption, changes in the empty container rules, a potential reduction in generator status, and the requirement for SQGs and LQGs to register within certain timeframes. &nbsp;Approximately 50% of states have already adopted Subpart P, with the rest following within the next year or so. Whether you are playing catch up or want to get ahead of the curve, this webinar is for you!&nbsp; <hr> <img alt="C Smith Head shot" data-entity-type="file" data-entity-uuid="26679999-b880-4765-953a-1d62f1801ff6" src="/sites/default/files/inline-images/Smith_C.png" width="275" height="273"> <h3>Presenter: Charlotte A. Smith, R. Ph., M.S., Senior Regulatory Advisor, PharmEcology Services, WMSS.&nbsp;</h3> &nbsp; Charlotte Smith, R. Ph., M.S. is Senior Regulatory Advisor, PharmEcology Services, a business unit of WM Sustainability Services. She founded PharmEcology Associates, LLC in 2000 and sold the company to Waste Management in 2009. &nbsp;She co-founded Capital Returns, Inc., a nationally known pharmaceutical reverse distributor in 1991 and for 10 years served as president and chief regulatory advisor. &nbsp;Ms. Smith is a registered pharmacist who received her BS in Pharmacy and MS in Continuing and Vocational Education from the University of Wisconsin. &nbsp;She is a member of the Pharmacy Society of Wisconsin, the American Society of Health-System Pharmacists, and the American Society of Consultant Pharmacists. Thu, 11 Mar 2021 08:24:45 -0600 Operations Related to Waste Management Workplace Hospital Waste Streams – Managing What Goes Out the Back Door /hospital-waste-streams-managing-what-goes-out-back-door <h1>Workplace&nbsp;Hospital Waste Streams – Managing What Goes Out the Back Door</h1><h3>By Ed Barr</h3>January 11, 2021&nbsp;|&nbsp;Formats:&nbsp;Technical Paper |&nbsp;Content Areas: Workforce&nbsp;|&nbsp;Tags: Hospital waste, Medical Waste Management, Waste Stream&nbsp;<hr>Although ancillary to a hospital’s core mission of healing, improving, and saving lives, the management of hospital waste streams has an undeniable impact on both the day-to-day operation of the facilities, and on longer-term matters like budgeting and sustainability. This document briefly examines the current state of the industry, and considers the identification and implementation of improved waste management practices.&nbsp; &nbsp;<div class="col-md-8"><div><h4 class="text-align-center">Access Today</h4>To view this resource, complete the form below:&nbsp;MktoForms2.loadForm("//sponsors.aha.org", "710-ZLL-651", 2934);</div></div>&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp; Tue, 12 Jan 2021 13:14:35 -0600 Operations Related to Waste Management 91��2017 Webinar: Hazardous Waste Pharmaceuticals /ahe-2017-webinar-hazardous-waste-pharmaceuticals <h1>2017&nbsp;91��Webinar</h1> <h2>Hazardous Waste Pharmaceuticals: EPA's Proposed Rule Change</h2> <hr /> Release Date: March&nbsp;2017 Cost: Free <a class="btn btn-primary btn" href="https://ams.aha.org/EWEB/?ahabu=AHE&amp;Action=Add&amp;ObjectKeyFrom=1A83491A-9853-4C87-86A4-F7D95601C2E2&amp;WebCode=ProdDetailAdd&amp;DoNotSave=yes&amp;ParentObject=CentralizedOrderEntry&amp;ParentDataObject=Invoice%20Detail&amp;ivd_formkey=69202792-63d7-4ba2-bf4e-a0da41270555&amp;ivd_prc_prd_key=68a88f24-5155-48ab-a6a9-375ef3662623&amp;_ga=2.222604627.954988668.1559568848-620121517.1547669993" role="button">Register</a> Presenters from the Environmental Protection Agency (EPA) provide information on the Proposed Rule: Management Standards for Hazardous Waste Pharmaceuticals. This rule proposes a tailored, sector-specific set of regulations for the management of hazardous waste pharmaceuticals by health care facilities (including pharmacies) and reverse distributors. It will provide standards to ensure the management of hazardous waste pharmaceuticals is safe and workable within the health care setting. Presenters: Mel Smith Education Specialist Kristin Fitzgerald Pharms Rule Lead Jessica Young Branch Chief Fri, 07 Jun 2019 10:10:27 -0500 Operations Related to Waste Management 91��2018 Webinar: Introduction to Solid Waste Management /ahe-2018-webinar-introduction-solid-waste-management <h1>2018 91��Webinar</h1> <h2>Hospital "Trash Talk": An Introduction to Solid Waste Management in Health Care Facilities</h2> <hr /> Release Date: Wednesday, May 23, 2018 Cost: 91��Members FREE; Non-members $79.00 <a class="btn btn-primary btn" href="https://ams.aha.org/EWEB/?ahabu=AHE&amp;Action=Add&amp;ObjectKeyFrom=1A83491A-9853-4C87-86A4-F7D95601C2E2&amp;WebCode=ProdDetailAdd&amp;DoNotSave=yes&amp;ParentObject=CentralizedOrderEntry&amp;ParentDataObject=Invoice%20Detail&amp;ivd_formkey=69202792-63d7-4ba2-bf4e-a0da41270555&amp;ivd_prc_prd_key=96e12577-e5c2-4b89-9722-9e6612ddfa27&amp;_ga=2.202155865.954988668.1559568848-620121517.1547669993" role="button">Register</a> One of the most difficult challenges faced by health care environmental services managers is to develop programs to manage waste material in a manner that is prescribed by law; safe for workers, the public, and the environment; and demonstrates economic stewardship. This session explores the identification of waste streams common to health care facilities: basic federal regulatory framework and liabilities as they pertain to waste management; methods to manage regulated waste, such as hazardous waste, pharmacy waste, medical waste and PHI; as well as some perspectives on waste minimization.&nbsp; Presenter: <img alt="Lloyd Duplechan" src="http://www.ahe.org/Shared_Images/Headshots/Duplechan_150.jpg" /> Lloyd Duplechan CEO/Principal of D&amp;A Healthcare Consultants Fri, 07 Jun 2019 09:49:46 -0500 Operations Related to Waste Management Leveraging Technology to Hire for Fit and Create an Environmental Culture of Care /leveraging-technology-hire-fit-and-create-environmental-culture-care <h1>Leveraging Technology to Hire for Fit and Create an Environmental Culture of Care</h1> <h3>By Pamela S. Starlin</h3> November 6th, 2018&nbsp;|&nbsp;Formats:&nbsp;Technical Paper |&nbsp;Content Areas:&nbsp;Administration&nbsp;|&nbsp;Tags:&nbsp;Environmental hygiene and sanitation, Waste Management and Sustainable Operations <hr /> The traditional role of the environmental services attendant must transition into the role of an adequately trained infection preventionist and, equally important, a hospitality ambassador. The patient's interaction and comfort with the environmental services attendant has a substantial impact on the overall perception of cleanliness and the competence of the staff member. Hiring for fit and being able to identify the natural born connectors and promoters among the task-oriented individuals normally drawn into the environmental services role becomes paramount.&nbsp; &nbsp; <div class="col-md-8"> <div> <h4 class="text-align-center">Access Today</h4> If you do not have member access, complete the form below to view this resource. If you are a member, login and access the technical paper through Key Resources on this page. &nbsp; MktoForms2.loadForm("//sponsors.aha.org", "710-ZLL-651", 2943); </div> </div> &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; &nbsp; Tue, 06 Nov 2018 12:00:06 -0600 Operations Related to Waste Management Sustainability and Compliance /sustainability-and-compliance <h4>By Debra Gillmeister, MBA</h4> September 23, 2013 | Formats: Article | Content Areas: Environmental Sanitation Operations, Regulatory Compliance | Tags: Chemicals , Policies, Regulatory Compliance, Sustainability, Waste Management and Sustainable Operations <hr> Healthcare facilities can generate up to 25 pounds of waste per day per patient. (1) Hospital leaders recognize the large amount of waste is a consequence of operating around the clock. Priorities are shifting to achieve a balance of sustainability and compliance that pushes environmental boundaries with commitments to improving air and water quality. Many regulatory standards for properly managing waste were set in motion beginning in 1976 followed by RCRA, and then the Clean Water Act, the Safe Drug Disposal Act, and the Hospital Medical Infectious Waste Incinerator Rule, to name a few. Yet the average number of regulatory compliance issues (The Joint Commission, OSHA, EPA, and/or Department of Transportation) uncovered during a typical hospital compliance review is 23. (2)&nbsp; To 91��members at the EXCHANGE 2012 conference, Laurie Leon, director of materials management at Boca Raton&nbsp;Regional Hospital, highlighted that 90 percent of hospitals could not readily pull together cost and weight data for their waste streams. This reality can lead to financial pressure. No Single Department is Responsible for Managing Waste “There is no single department responsible for managing waste. What is positive is that hospitals are taking a currently decentralized model for managing multiple waste streams and streamlining it into an integrated model,” she noted. “When I ask facility leaders how many soap dispensers or surgical kits they ordered last year and the total spent, they can answer in a few clicks. When I ask: ‘What was your total waste spend last year?’ everyone looks around the room,” said Leon. Why? Many departments are responsible for different waste streams. “Environmental services (EVS) professionals usually manage the bulk of medical waste and solid waste. EH&amp;S or the facilities department might be responsible for the hazardous waste streams. And engineering typically takes construction waste,” Leon concluded. (2)&nbsp; When the process of managing waste is segmented, a great burden is placed on EVS teams. Cross functional collaboration and communication between many departments within the hospital is critical. Education Changes Culture Identifying ways to stay compliant while becoming sustainable often means implementing a green team and educating staff to stop looking at waste as ‘waste’ when items such as desks, chairs, water pitchers, cups, laptops, and iPads are recyclable. Managing 10 to 12 waste streams, 80 percent of which are highly regulated, is not an easy task. The process involves clinical and non-clinical departments and requires a significant culture change, no matter the size or location of the hospital. Segregation and waste stream diversion standards help redirect waste to drive better economics and sustainability efforts. 91��member, Yale-New Haven Hospital Environmental Services Team Lead&nbsp;Robert Frankel noted, “There is a massive opportunity for waste reduction and sustainability within hospitals. Rounding with managers and speaking with staff helps make sure that things are being disposed of in the appropriate waste stream. Education is critical to focus on getting bandages, gloves, and other normal trash materials out of the red bags and into the clear bags or containers where they belong.” Keep Drugs Out of the Public Water System It is important for EVS teams to know what waste they are handling, whether it is hazardous or nonhazardous, and the process of signing the appropriate manifests or DOT shipping papers. The EPA has specific management requirements for hazardous waste. For instance, medications such as warfarin (Coumadin) and nicotine must be kept out of the water supply and therefore should be discarded in separate, designated containers that require responsible disposal by a properly licensed company. Either way, several guidelines help you better understand the risks. <ol> <li>Understand which state or federal regulations impact drug disposal;</li> <li>Protect your community by not allowing narcotics to be diverted; and</li> <li>Properly store waste on site and restrict accessibility to unauthorized personnel.</li> </ol> The issues of pharmaceuticals polluting the waterways were highlighted in the early 2000s with the U.S. Geological Survey (USGS) Water Survey finding substances in&nbsp;80 percent of tested streams. Roughly one third of those contaminants were pharmaceutical substances which prompted close examination of how hospitals dispose of pharmaceuticals and how they affect Americans. Regulatory and legislative bodies have begun establishing and enforcing strict hospital waste guidelines. This increase in regulatory oversight has left hospital leaders challenged to understand what their role and responsibilities are and how to avoid costly fines and citations. \ Combined with keeping drugs out of the water, hospital leaders and EVS professionals also desire to keep containers that carry pharmaceutical waste out of landfills. At Beebe Medical Center (BMC) in Lewes, Del., a 24-month case study (2) of reusable pharmaceutical containers tracked the reuse rates for 2,184 containers serviced. Ninety-seven percent of the reusable containers were eight-gallon and 17-gallon. By utilizing reusable containers, BMC diverted between 3.7–5.0 tons of plastic from disposal, therefore minimizing landfill contributions and reducing hospital disposal costs. Proactive, Reusable Sharps Container Services Don’t Always Add Labor Costs An often overlooked component of reducing waste includes the waste containers such as reusable sharps containers. Yale-New Haven Hospital switched from using disposable to eco-friendly reusable sharps containers. The solution creates a “win-win” for the facility said Frankel. “Staff&nbsp;safety is improved due to the container’s user-friendly ‘point and drop’ design. The container is a FDA-regulated medical device, which can be reused 600 times creating a greener, more sustainable solution. We use a company that manages proactive container exchange, so EVS teams and hospital staff no longer have to replace filled containers. This service decreases labor, and we have realized a 25 percent reduction in regulated medical waste,” said Frankel. The Dana Farber Cancer Institute, Boston, Mass., has a clinical program devoted to cancer care. “All of the clinical sharps containers are sent for incineration as trace chemotherapy. However, most of the sharps from our basic research program are diverted to the reusable sharps container service to improve our carbon footprint,” explained Karen Byers, biosafety officer. “We implemented the proactive container exchange service, very cautiously at first, on one research floor for three months. We then expanded the service to one building on another campus and then expanded to our research community. The statistics speak for themselves. In 2012 we diverted 6,562 pounds of plastic and 515 pounds of cardboard from the landfill, which prevented the emissions of 3,896 pounds of CO2. These numbers are the equivalent of not burning 201 gallons of gas or 74 propane cylinders for home barbeques.” (3) Byers noted that the service has resulted in considerable time savings. “Previously, researchers had to order disposable sharps containers, monitor the level of sharps in the container, replace as required, and then request pickup of the full container. Now the process is automatic—the container exchange partner comes in, removes containers, and replaces them. This is working well.” Byers noted that the service has resulted in considerable time savings. “Previously, researchers had to order disposable sharps containers, monitor the level of sharps in the container, replace as required, and then request pickup of the full container. Now the process is automatic—the container exchange partner comes in, removes containers, and replaces them. This is working well.” <img alt="Managing hospital waste streams is a complex process" data-entity-type="file" data-entity-uuid="1d561544-3c16-4461-b1e1-77014a187270" src="/sites/default/files/inline-images/SustainabilityandCompliance.png" width="686" height="453"> References <ol> <li>www.sustainabilityroadmap.org/topics/waste.shtml#.Udq-_ax2nqQ</li> <li>Stericycle, Inc.</li> <li>www.stericycle.com/carbon-footprint</li> </ol> Mon, 23 Sep 2013 10:16:26 -0500 Operations Related to Waste Management Finding Your Road to Sustainability /finding-your-road-sustainability <h4>By Stephen Ashkin</h4> September 23, 2013 | Formats: Article | Content Areas: Environmental Sanitation Operations | Tags: Sustainability, Waste Management and Sustainable Operations <hr /> There’s nothing complicated about the term Green Cleaning. It simply means cleaning to protect health without harming the environment. It can refer to the use of cleaning chemicals, tools, equipment, and other products that have a reduced impact on health and the environment when compared to conventional cleaning products used for the same purposes. It can also refer to methodologies and cleaning systems that incorporate these items. There are many benefits to Green Cleaning, and these benefits have become more apparent in recent years as a result of documentation and scientific evidence. For a variety of reasons, though, it has been more difficult for some sectors to embrace Green Cleaning strategies. Roadblocks to Adoption Because of its many benefits, education, commercial offices, and the hotel/hospitality industry have all moved quickly to adopt Green Cleaning strategies. Implementation at healthcare facilities, however, has been much slower. There are many reasons for healthcare’s slow adoption to embrace Green Cleaning. For one, healthcare facilities have far different cleaning needs than virtually any&nbsp;other type of facility. Consider the difference in these scenarios: while a school may become concerned if several children come down with the flu in a short period of time, a hospital could potentially have to shut down entire wards if there is a significant uptick in the number of healthcare associated infections (HAIs). Because of concerns about jeopardizing patient or staff health, many hospital administrators and infection prevention personnel are hesitant to make any changes to their cleaning practices or the type of cleaning products they select. Sustainability and Green Cleaning have become intertwined. How a product is made, the ingredients used in its formulation (whether they are from renewable sources), how it is packaged (with recycled and recyclable materials), even how concentrated it is, and the size of the container—all of these “green” characteristics support sustainability. Roadmap to Greener Healthcare&nbsp; So how can more healthcare facilities implement Green Cleaning strategies given the concerns and the roadblocks they face? The following is a roadmap for institutions interested in developing a Green Cleaning program. This two-pronged roadmap includes a care-zone&nbsp;approach to cleaning, followed by selecting the appropriate products. The first step when it comes to implementing a Green Cleaning program in healthcare facilities starts by dividing a facility into three key zones: Non-critical care zones: Includes administrative areas, meeting rooms, shopping areas as well as entryways, hallways, and others areas in most buildings. Due to the concerns of many infection prevention professionals, hospitals often begin their Green Cleaning initiative by focusing on those areas with the lowest risk to health. These areas often represent as much as 70–90 percent of the hospitals square footage. Critical care zones: These areas are occupied by the most vulnerable occupants including some patient rooms, surgical areas, ambulances, and emergency rooms. These critical-care zones require intensive cleaning in terms of time and effort due to the associated risk of harm to patients and other building occupants in these areas, as compared to the semi-critical and non-critical zones. Semi-critical care zones: Areas such as restrooms, physical therapy rooms, non-emergency clinics, and patient areas where a high level of sanitation is needed, though not necessarily disinfection. The&nbsp;process of identifying which areas are assigned to this zone is typically completed after assigning the critical care and non-critical care zones. Once those at the extreme have been assigned, often those areas left over are assigned to this zone. Success in healthcare is often associated with just getting started. Beginning in the non-critical care zone is easiest because it is often the first place to gain support from infection control and other departments because the risk of harm to patients is the lowest. This also allows for products to be tested for performance, identify proper&nbsp;dilution rates, train environmental service personnel, and address cost-related issues. Keep in mind that healthcare facilities can reduce environmental impacts associated with the cleaning program without changing its use of chemicals and disinfectants. Often starting by greening general cleaners, carpet and floor care products, sanitary paper, equipment, plastic trashcan liners, and other products. There are numerous ways to impact sustainability in the healthcare setting that don’t require a sudden change in service providers, and products and services used. Selecting Products While it has been a relatively slow process, more healthcare facilities are finding ways to green their operations. Organizations such as 91��and Practice Greenhealth have helped move this process along immeasurably in healthcare, while other organizations promote similar programs in specific segments such as the U.S. Green Building Council’s LEED Rating System for Existing Buildings (LEED-EBOM) for office buildings, the Healthy Schools Campaign in schools, and the Green Sports Alliance in sporting stadiums and athletic venues. And each of these organizations provides recommendations on standards that can be used to identify greener cleaning products and equipment. For example, LEED-EBOM provides a comprehensive list of independent third-party standards from Green Seal, EcoLogo, Ecoform, EPA’s Design for the Environment Program, and the Carpet &amp; Rug Institute that validate the health and environmental attributes, along with product performance, which makes it easier to buy products with confidence. Plus, hundreds of suppliers of cleaning products use these standards, which means that the products are widely available and competition has made them very cost effective. The approach of dividing a hospital into care zones and using the most appropriate chemicals, as well as other important components of a comprehensive Green Cleaning program such as high-filtration vacuums, micro-fiber cloths and mops, sanitary paper made from recycled or rapidly renewable fibers, and new technologies including vapor cleaners and devices that turn water into an effective cleaning and sanitizing solution, can all help achieve our goal of creating safer and healthier indoor environments while reducing negative environmental impacts. Mon, 23 Sep 2013 09:35:00 -0500 Operations Related to Waste Management Drugs and the DEA /drugs-and-dea <h4>By Charlotte A. Smith, RPh, MS</h4> September 23, 2013 | Formats: Article | Content Areas: Regulatory Compliance | Tags: Chemicals , Regulatory Compliance, Waste Management and Sustainable Operations <hr /> The abuse of prescription drugs, particularly controlled substances regulated by the Drug Enforcement Administration (DEA) as “drugs of abuse,” has reached epidemic proportions, exceeding that of traditional illicit drugs in all cases except marijuana. (1) Many of these drugs are obtained not from shadowy drug dealers on street corners but from the medicine cabinets of parents and grandparents. Due to the “closed loop” nature of the current Controlled Substances Act, these drugs cannot be returned to a pharmacy or other healthcare provider but must be delivered directly to law enforcement. Community take-back programs must have a law enforcement officer present to receive the controlled substances, making these events more costly and difficult to organize. For the short term, DEA has responded to the need to remove these drugs from the market by establishing bi-annual “take back days,” usually in the fall and spring. (2) Seeking a long-term solution, Congress passed the Safe and Responsible Drug Disposal Act of 2010 (3) that amends the Controlled Substances Act to enable additional methods for the management and disposal of unwanted consumer-controlled substances. DEA was charged with writing the specific&nbsp;regulations under the Act and published its “notice of proposed rulemaking” on December 21, 2012. Interested parties were asked to comment by February 19, 2013. According to the DEA Diversion website, (4) “The proposed regulations contain specific provisions that: <ul> <li>Continue to allow law enforcement agencies to voluntarily conduct take-back events, administer mail-back programs, and maintain collection boxes;</li> <li>Allow authorized manufacturers, distributors, reverse distributors, and retail pharmacies to voluntarily administer mail-back programs and maintain collection boxes; and</li> <li>Allow authorized retail pharmacies to voluntarily maintain collection boxes at long-term care facilities.”</li> </ul> So how does this proposed regulation impact your hospital environment? Interestingly enough, DEA chose this opportunity to clarify, and in some cases tighten, rules for disposal of controlled substances within healthcare settings, including hospitals and long-term care facilities (LTCFs). While these proposed regulations are not yet finalized, it’s important to understand what has been proposed. The challenge in the hospital setting is to balance concerns about diversion by staff and visitors with DEA, EPA, and other regulatory requirements. With respect to community take-back events, it’s not clear whether a hospital may offer a public take-back event, as some&nbsp;have in the past. What is clear is that a retail pharmacy located within a hospital may have a kiosk located within the pharmacy itself, but a hospital may not offer a kiosk in any other area. DEA’s reasoning is that the pharmacy is a more controlled environment under the close supervision of pharmacists and staff. DEA anticipates the retail pharmacy will ship the controlled substances to a reverse distributor for eventual destruction. Of special interest to hospitals will be the proposed regulations regarding the destruction of unused controlled substances generated during patient care. For example, DEA proposes that the destruction of a controlled substance, such as occurs routinely by nurses, be documented on a DEA Form 41. This form, even if modified, is a paper document and would require the signatures of two nurses or other healthcare professionals. Currently, such “double witness” documentation is performed electronically through the automated dispensing machine, such as Pyxis, Omnicell, etc. Requiring a paper format would be incredibly cumbersome and would eliminate the automated checks and balances in the current system. In addition, the proposed regulations require such witnesses of destruction to be “authorized employees” who are working as full-time employees. In today’s healthcare environment, both pharmacists and nurses are often part-time or working from a professional pool. Of even more concern is DEA’s proposed standard of destruction—nonretrievable—which reads as follows: “‘non-retrievable’ means to permanently&nbsp;alter any controlled substance’s physical and/or chemical state through irreversible means in order to render that controlled substance unavailable and unusable for all practical purposes.” Incineration and chemical digestion are cited as examples of qualifying technologies. While DEA is well-intentioned by not requiring a particular method of destruction, by not defining more specific parameters, inventors and entrepreneurs who DEA expects to create alternatives will be left in limbo as to what constitutes non-retrievable. Likewise, hospitals and other healthcare facilities will be unsure what current and future systems should be used to comply with the regulations. This ambiguous situation is made even more urgent by an earlier statement in the proposed regulations that “Flushing and mixing controlled substances with coffee grounds or cat litter are examples of existing methods of destruction that do not meet the non-retrievable standard.” While we can all appreciate that flushing is the least desirable method from an environmental perspective, it would certainly render the drugs non-retrievable “for all practical purposes” as required by the proposed regulations. In the past, the director of pharmacy would request a blanket approval for destruction for controlled substances within the hospital. In the proposed regulation, the DEA Special Agent In Charge may authorize blanket approval for disposal but periodic reports would need to be filed and the controlled substances delivered to a reverse distributor. This process seems to contradict the concept of rendering the controlled substances non-retrievable at the facility. There are two additional areas that have not been addressed in the new regulations that are important to hospitals. The first involves how to handle controlled substances brought in by patients if the drugs cannot be returned to the patient upon discharge. Currently, some hospitals send these drugs to a reverse distributor, although the drugs are technically already out of the closed loop, or the hospital may&nbsp;dispose of the drugs themselves with two witnesses, through either sewering, solidification, or some other method. Hopefully DEA will provide a clear avenue for the management of these abandoned drugs in the final regulations. The second area of great concern to hospitals is how to dispose of used fentanyl patches, which still contain enough drug to be attractive to those seeking such drugs and to be a poisoning risk to visitors, especially small children. Many hospitals currently have nurses fold the patches up and cut them into smaller pieces, then dispose the patches into a restricted entry red sharps or pharmaceutical waste container. Nurses should be trained never to dispose of the used patches in either the trash or the redbag waste for both diversion and safety reasons. A number of healthcare organizations now include LTCF, assisted living, and independent living units as part of their overall corporate structure. Disposal of controlled substances in LTCFs is very specifically addressed in the proposed regulations. The new regulations enable LTCF provider pharmacies to place drug return kiosks at the LTCF for the collection of controlled substances and perhaps other drugs. Only pharmacy personnel may access and remove the inner containers. Two full-time pharmacy employees must be present to access and remove the collected drugs and return them to the pharmacy, where they will presumably be shipped to a reverse distributor for additional processing and eventual destruction. There is no requirement that provider pharmacies offer this service, however, and there are no other alternatives provided to LTCFs. Again, this well-intentioned plan may work at a majority of LTCFs, but alternatives should be available if needed. There is also no discussion of the cost of these programs and who will bear that cost. The proposed regulations are also silent with respect to disposal options for assisted living arrangements where caregivers manage medication administration and disposal. The assumption may be made&nbsp;that those residing in independent living situations would be able to dispose of their own medications through community takeback events or the new retail options. We know this is not always the case, however. Many organizations and associations, including the 91��, have offered their thoughts and suggestions during the 60-day response period. Hopefully DEA will take these ideas under consideration as the final rule is prepared. Regardless, it will be very important that the management teams at each hospital carefully review the final rule since it will most likely contain important changes for controlled substance management. From the viewpoint of environmental service professionals, you and your employees are the first line of defense if controlled substances are disposed of inappropriately in the trash or even as redbag waste. Ensure your employees are completely informed of your hospital’s pharmaceutical waste management program and encourage them to be constantly aware of any inappropriate disposal practices. Only by constant vigilance will any program of this complexity and importance succeed. And stay tuned for the final regulations implementing the amended Controlled Substances Act. These regulations will impact us all! Mon, 23 Sep 2013 09:19:05 -0500 Operations Related to Waste Management