Managing pharmaceuticals comes with its own unique set of challenges. Proper segregation and disposal are key, and the many regulations surrounding pharmaceutical waste management can be intimidating. Some typical examples of pharma waste include discontinued, unused, or expired medication, and sample medications. Specific examples would include over-the-counter pills, creams, vials, antibiotics and injectables. This type of waste is typically non-hazardous, with some exceptions (more on that, later.) How do you manage your unused and expired medications? Do you have a plan and system in place for properly managing pharmaceuticals and disposing of expired meds? Let’s look at why you need a plan and how to get started.
Improper Disposal of Expired Medications is Risky
It’s important to follow proper procedures for disposing of expired medications to ensure the safety of individuals and the environment. Improper disposal of expired meds can post several risks and potentially impact the safety of your staff and patients.
- Environmental contamination: Flushing expired meds down the toilet or drain can release pharmaceuticals into the water supply, potentially contaminating drinking water.
- Public health risks: Improperly disposed of medications might be accessible to at-risk people, potentially leading to accidental poisoning or overdose.
- Drug resistance: Incorrect disposal of antibiotics and other medications can contribute to the development of drug-resistant strains of bacteria and other microorganisms.
- Legal liability: There are legal consequences for improper disposal of expired meds, including fines and criminal charges, depending on the jurisdiction and specific circumstances.
These are the risks; here’s why you need a system in place to manage your expired meds.
Your Office Needs a Plan to Manage Expired Medications
Having a plan or system in place to manage expired medications will help ensure that all staff members know proper procedures for handling and disposing of them. This will reduce the risk of errors and increase the safety and efficiency of the process.
A system to manage expired medications should include the following steps:
- Regular checks of medication expiration dates to identify expired ones
- Separation of expired meds from current inventory
- Proper disposal of expired meds following guidance from the US Environmental Protection Agency (EPA) and state guidelines
- Documentation of the disposal process to ensure compliance with regulations and for record-keeping purposes
Now that you have a plan in place, let’s look at the disposal process to follow for compliance.
Important Questions for Managing Pharmaceuticals
Before we share some steps to follow, there are a few questions you’ll need to answer.
Controlled or Non-controlled?
Knowing whether or not a waste product is a controlled substance is key to proper pharmaceutical waste disposal procedures. Controlled pharmaceutical drugs are regulated by the Drug Enforcement Agency (DEA). They are classified into five distinct categories, or schedules, and range from drugs with a high potential for abuse such as Vicodin down to cough medicines with small doses of codeine, for example. These waste products must be separated from all other pharmaceutical waste and sent to a DEA-registered reverse distributor (unless your facility is a DEA registrant.)
Hazardous or Non-Hazardous?
Once non-controlled pharmaceutical drugs become waste products, they are regulated by the Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA) program. Under this program, they are separated into two categories: Hazardous and non-hazardous. It’s important to know that most non-hazardous waste is still not harmless and can not be mixed with general waste. Here’s how to identify non-RCRA pharma waste.
Creditable or Non-creditable?
Many pharmaceutical companies offer take-back programs for creditable pharmaceuticals. However, prescription hazardous waste pharmaceuticals that don’t have a reasonable expectation to be eligible for a credit as well as those that are nonprescription that will probably not be legitimately used, reused or reclaimed must be sent to a designated facility for disposal, according to the Alabama Department of Environmental Management (ADEM). Here are ADEM’s guidelines for managing non-creditable hazardous waste.
Here are the Tennessee Department of Environment & Conservation’s (TDEC) guidelines for reverse distribution for unused and unopened pharmaceuticals and managing hazardous pharmaceutical waste. Check for specific regulations for your state. Some states have their own regulations, which may be more stringent than the federal guidelines.
Once you’ve made the above determinations, here are ten steps that will be helpful in managing pharmaceuticals and properly disposing of your unused and expired medications.
10 Steps to Manage and Clean Out Expired Medications
- Check medications monthly for: outdates, deterioration, and appropriate location. Inspect all medication storage areas, including refrigerators.
- Do not reuse or share expired medications, as they may be less effective or potentially harmful.
- Check for disposal instructions on the medication label or packaging.
- Segregate your waste. This means separating medications from your other regulated medical waste (RMW) or “red bag” waste.
- Remove personal information from any patient prescription labels when disposing of unused medications.
- Use take-back programs. Many pharmaceutical manufacturers and reverse distributors offer these programs to properly dispose of expired medicines.
- Avoid flushing medicines down the drain or toilet.
- Use medication disposal containers. These are designed to safely dispose of expired and unused medicines. Non-haz pharma, or blue bin waste, can be disposed of in a blue or green container, or in a container that is clearly marked as “non-hazardous.”
- Keep a record of all disposed medications, including the type of medicine, quantity, and date of disposal.
- Review procedures and train employees on a regular basis as part of an overall medical waste management plan.
When Managing Pharmaceuticals:
- Remember that ALL pharmaceutical waste, including expired and unused medications, must be disposed of separately from red bag waste.
- Make sure your pharmaceutical waste is destroyed using the correct incineration method.
- Get a certificate of destruction and keep a paper trail for your pharmaceutical waste.
- Place expired or unused medications in sharps boxes.
- Mix hazardous and non-hazardous pharmaceutical waste.
- Co-mingle expired or unused medications with your other RMW.*
*This is very important. Pharma waste should not be treated. All pharma waste should be incinerated for proper disposal.
By following these guidelines, you can ensure that your medical practice safely manages unused and expired medications as part of a compliant pharmaceutical waste management program. Have questions about managing pharmaceuticals? TriHaz Solutions offers waste profiling services and free consultations. Learn more about our pharmaceutical waste management services.