The Pharmaceutical Waste Rubik’s Cube — Part 1: Defining the Pharmaceutical Waste Rubik’s Cube
In recent years, the issue of what do with Pharmaceutical Waste, aka “expired medications,” is one that has come to the forefront for healthcare operators. Previously, it was acceptable to flush pharmaceutical waste down the toilet, combine them with regulated medical waste, or combine them with kitty litter and dispose of them in the trash. However, the EPA has become more stringent in enforcing federal regulations, and redefining said regulations, with respect to how expired medications should be disposed of. Flushing of pharmaceutical waste is no longer an accepted practice, and if the generator’s medical waste disposal company discovers that pharmaceutical waste is being combined with regulated medical waste, they will inform the generator that said medications need to be removed from the medical waste, or they will no longer pick up the medical waste.
The current problem facing healthcare operators is that there is a hodgepodge of federal regulations and guidelines that have been passed since the 1970’s and the EPA is just now getting around to enforcing some, and redefining other regulations. Throw into the mix the fact that the individual states are allowed to go beyond the federal guidelines and be even more stringent than the federal regulations, and you have the crux of what we like to call here “The Pharmaceutical Waste Rubik’s Cube” at Waste Experts.
Let’s look at an example of the problem. Assume you are a nursing home operator with locations in four states. State A only goes by the federal guidelines and barely enforces them. State B goes beyond the federal guidelines and is very stringent in enforcing the federal and their own state guidelines. To make it even worse, your medical waste vendor in State C notifies you that your locations are combining pharmaceutical waste with regulated medical waste, and now they want you to implement an additional disposal program that charges a flat monthly fee. And, oh, by the way, that fee only includes two containers a year and if you exceed the two containers, each additional container is $500.00!
Last, but not least, State D decides to become more stringent in enforcing the guidelines and all of a sudden you are faced with having to put together a pharmaceutical waste disposal program on the fly. Of course you end up overspending, because the program is set up while in “crisis mode.” So now, in addition to being squeezed by Medicare cutbacks, the Affordable Care Act and rising operating costs, you have to deal with the prospects of implementing a Pharmaceutical Disposal program in at least three out of four states that they operate in.
In part two of this series, we will look at how you can review and implement a proper pharmaceutical waste disposal program. Already have this problem, and want a free review of your current medical and pharmaceutical waste disposal program? Contact us today!