Pharmaceutical Waste Management in Health Systems

							Facility & Department Information
Survey Methodology
Complying with the multiple, and often conflicting, regula-            35                              Facility Size
tions guiding pharmaceutical waste management is clearly a                         31%            (in number of beds)
significant challenge for health-system pharmacists. Often             30
current practices are based on old habits, rather than best
                                                                                                                                 Survey respondents
practices. Compliance is also complicated by decades-old               25                                                     represent a cross-section
regulations that have not kept up with an-ever changing                                       21%                             of hospital sizes.
pharmacy environment.                                                  20
                                                                                                                   17%
                                                                                                         17%
   The first step to improving pharmaceutical waste manage-
                                                                                                                                  14%
ment is examining current practices. To do this, in the third          15
quarter of 2008, PP&P polled a random, nationwide sam-
pling of health-system directors of pharmacy. Responses                10
were solicited via e-mail and a total of 205 were received,
yielding a confidence interval of 6.71% (95% +/-6.71%),                 5
based on the total population of pharmacy directors nation-
wide. Respondents represent a cross-section of hospital                 0
pharmacy practitioners.                                                           1-100     101-200    201-300     301-500        500+
   Just as the EPA is now looking to define current practices
in waste management, PP&P undertook this survey to identi-
fy common practices and highlight some of the areas in need                                 Respondents’ Titles
of improvement within pharmaceutical waste management.                   80
                                                                                      75%
                                                                         70

                                                                         60                                    KEY: Titles
                                                                                                                 Director of pharmacy
                 Facility Location
                                                                         50                                      Pharmacy manager
                                                                                                                 Assistant director of pharmacy
                                                                         40                                      Other
                   36%
                   Urban           39%                                   30
                                   Rural
                      25%                                                20
                      Suburban                                                                   12%
                                                                                                                             8%
                                                                         10                                   5%

                                                                            0

           Responding facilities were distributed
         among rural, suburban, and urban locations.                               The vast majority of respondents were DoPs. Among those
                                                                                reporting in the “other” category were vice presidents of phar-
                                                                                macy, supervisors, IV pharmacists, and purchasing pharmacists.




           Acknowledgements

           Pharmacy Purchasing & Products is pleased to publish the results of our Pharmaceutical Waste Management
           Survey, which examines commitment levels and current waste management practices in hospital pharmacy
           today. We would like to thank the many pharmacy leaders who took the time to complete the questionnaire and
           share their approaches to waste management.

           PP&P also gratefully acknowledges Vestara for its generous sponsorship of this study.




2 I Pharmaceutical Waste Management I 2008
                                                                                     By Firouzan “Fred” Massoomi, PharmD, FASHP




Pharmacy’s Ownership of
Pharmaceutical Waste Management
        n light of the recent AP report on US drinking water tainted with phar-      reviewing drugs to be on formulary, we need to put the same effort into drug



I       maceuticals and increasing regulatory fines, the need to establish com-
        prehensive pharmaceutical waste management programs has become a
        pressing issue for pharmacy. Achieving regulatory compliance by
        identifying the appropriate waste streams for drug waste and managing
the segregation process must be a priority for all health systems. As the res-
ident in-house pharmaceutical experts, it is key that pharmacists not only
participate in this process, but that we actually drive the change. Not because
                                                                                     disposal and worker safety.

                                                                                     Budgeting
                                                                                     Making a commitment to properly managing pharmaceutical waste requires a
                                                                                     budget commitment as well. Currently, very few hospitals have a line item in
                                                                                     their operating budget for managing pharmaceutical waste. Of those who do,
                                                                                     most are committing very few dollars. Consider, for example, that 200-bed hos-
we have to, but because it is the right thing to do.                                 pitals spend $7,500 annually, on average, to manage their pharmaceutical waste.
    Facilities that improperly dispose of drug waste run the risk of damaging the    For a hospital with an annual drug budget of $5 million, that means approximate-
environment and incurring significant regulatory fines. RCRA violations for          ly .002% of the drug budget is being spent to manage the resultant waste. In addi-
example, can result in fines of up to $32,500 per violation, per day. In addition,   tion, I find it alarming that 33% of respondents have no plans to establish a budg-
OSHA’s Hazardous Communication Standard requires that all employees work-            et for managing pharmaceutical waste. We have to do better than this. Compliant
ing with hazardous chemicals receive training and PPE; should they not receive       waste management cannot be attained without the commitment of pharmacy,
these, they have the right to sue their employer. Outsourcing your waste dispos-     hospital administrators, and resources.
al may simplify some of your processes, but you cannot outsource your respon-
sibility to assure compliant procedures are followed. Just as you train your hos-    Waste Management Resources
pital staff in proper and safe disposal methods, you should think about educating    Not surprisingly, many survey respondents complained about a lack of good
outsourced employees as well. Remember, you own the waste you generate until         sources for training staff on compliant waste disposal. I recommend starting
it is 100% destroyed and the burden of liability for the safety of outsourced        with the ASHP Advantage’s ACPE accredited Pharmaceutical Waste
employees falls on the hospital.                                                     Management Issues and Options for Health Systems, updated in October 2008,
                                                                                     which is supported through an educational grant from Vestara. For more infor-
Pharmaceutical Waste Management Practices                                            mation, visit http://symposia.ashp.org/pharmawaste. In addition, an excellent
In the survey results, it is heartening to see that a clear majority of DoPs are     resource guide on pharmaceutical waste management strategies and audit
aware that collecting all pharmaceutical waste, including hazardous and non-         worksheets are available free of charge at www.safersolutions.org. Consider
hazardous, in one container on the floor and segregating it on the loading dock      including pharmaceutical waste management in your annual hospital safety
is both poor practice and illegal. However, the survey results also demonstrat-      review to ensure your staff is continually engaged. Achieving compliant phar-
ed a wide range of disposal methods currently in use, and many facilities            maceutical waste management is imperative for the safety of our water supply
reported improperly disposing of drugs, such as putting warfarin >0.3%               and our health, and pharmacy needs to lead this process. We should not wait
(RCRA P001) in the regular trash. Just as pharmacy does an excellent job             for regulations to drive an initiative, especially one we can control. I




                                 Awareness of Upcoming EPA Mandated Questionnaire


                                             18%                             The EPA is in the process of developing a detailed questionnaire on
                                             Yes                          pharmacy waste practices that will soon be disseminated to one in
                          82%                                             every five US hospitals. Given that this initiative is in development, it is
                          No                                              not surprising that few DoPs are familiar with it. However, recipient
                                                                          hospitals will be required to complete, certify and return the question-
                                                                          naire to the EPA, underscoring the importance of staying abreast of
                                                                          pharmaceutical waste management issues.




                                                                                                                   2008   I   Pharmaceutical Waste Management       I   3