December 9, 2021

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Kevin Webber
Why You Need a Pharmaceutical Waste Certificate of Destruction and Manifest

Any facility that generates medical waste has legal requirements it must meet when preparing for its disposal. One such provision is written evidence that pharmaceutical waste has been legally and correctly disposed of. If your facility is audited and this evidence is not available, you could face significant fines or worse.

Many medical waste generators we talk to aren’t aware that not every waste management company is licensed to transport hazardous pharmaceutical waste. And that when using one of these waste management companies, their waste may not be properly disposed of. Also, even when transporting non-hazardous pharma waste, a permit is still required from the State Board of Pharmacy.

Are you confident your medical waste transportation company is disposing of your facility’s pharmaceutical waste adequately? It’s best that you are, because any liability for improper disposal rests with you, the waste generator, not the waste management company you’ve hired to dispose of it. A comprehensive cradle-to-grave regulated waste management program that includes pharmaceutical waste certificates of destruction and manifests ensures your facility complies with RCRA legislation requirements.

What is a Pharmaceutical Waste Manifest?

A core component in safe pharmaceutical handling is proper waste management. The risks associated with improper disposal of medical drugs and chemicals are well-established and include:

  • Leaching into the surrounding environment that contaminates groundwater, drinking water, and plant life.
  • Health problems in the community.
  • Increased risk of drug misuse.

While a waste manifest is requried for all regulated medical waste (including non-hazardous pharma waste), the Hazardous Waste Manifest System established by the EPA and U.S. Department of Transportation is used for hazardous pharma waste. It requires all waste generators who transport or offer for transport hazardous waste, (including pharmaceuticals) for off-site treatment and disposal to file and keep on record a pharmaceutical waste certificate of destruction and manifest.

The hazardous waste manifest document accompanies RCRA-designated waste from your facility to its designated hazardous waste treatment, storage, or disposal facility. The manifest is filled out at the time of service and identifies:

  • Your facility as a waste-generating healthcare site.
  • What is being picked up (how many and what type of container).
  • The transporter, such as TriHaz, that carries the waste off-site.
  • The destination for the hazardous waste treatment, storage, disposal, or recycling.

As a generator of pharmaceutical waste, you are entirely responsible for the accuracy and completeness of the information entered on the manifest and it is signed by both you and the driver.

What Items Should Be In a Certificate of Destruction

From initial generation through transportation and final disposal, your facility is responsible for staying compliant with RCRA regulations. A certification of destruction is just one of the records that must be filled out and submitted when shipping hazardous waste. Together with the hazardous waste manifest, it allows you to track your pharmaceutical waste, ensures the waste has been disposed of properly, and provides information on where your pharmaceutical waste is taken.

A certificate of destruction should include:

  1. The name, address, and other information pertaining to the waste generator (your facility).
  2. A work order number.
  3. An invoice number.
  4. The date the pharmaceutical waste items were received.
  5. A detailed description of all items being transported for incineration.
  6. A legal statement from the waste management company confirming all materials comply with state and federal, DOT, EPA, and Department of Toxic Substance Control (DTSC) laws.
  7. An accuracy statement verifying the information in the certificate of destruction is accurate.
  8. The certified signature of an authorized pharmaceutical waste management and transport company representative.
  9. Certification of the date the certificate was issued to you by the hazardous waste disposal company.

Your staff should understand that no pharmaceutical waste can be taken to a landfill. And that to ensure your facility is properly managing hazardous waste streams, certain state and federal regulations must be met. That includes the incineration of all bulk and trace chemo waste, regardless of quantity—even trace amounts must be incinerated.

Manifesting Hazardous Waste Pharmaceuticals

Whether you manage a clinic, medical research lab, veterinary hospital, nursing home, or another facility that produces pharmaceutical waste, it’s your responsibility to be familiar with and follow applicable federal and state laws.

Working with an experienced, insured, and properly licensed hazardous waste transporter that offers both a certificate of destruction and a manifest provides you with the comfort and assurance you need to know the job is done legally and correctly.

If you’d like to know more about why you need a pharmaceutical waste certificate of destruction and manifest or to review which pharmaceutical waste documents you should keep on file, contact TriHaz today. As a licensed contractor for the disposal of hazardous and non-hazardous pharma waste, we can guide you on whether your facility is following and remaining compliant with all regulatory standards.

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