Managing the operations of skilled nursing or long-term care facilities requires attention to a range of requirements – especially when it comes to managing pharmaceuticals. Federal regulations governing the management of hazardous waste, including hazardous pharmaceuticals, are detailed within the Environmental Protection Agency’s Resource Conservation and Recovery Act (RCRA).
RCRA’s requirements for storage, transportation, and disposal of hazardous waste apply equally to all businesses, regardless of the industry they are in or the type of healthcare they provide. The Stericycle Hazardous Drug Disposal Services (HDDS) program is designed to address the Rx waste needs of a wide range of customers – including skilled nursing and long-term care facilities (LTCF), which often require a more customized approach.
1. Know the difference between Rx product and Rx waste.
Isn’t it all the same? No, in fact there are key differences. Rx waste is different from viable pharmaceutical products, which have creditable value when returned to the manufacturer or distributor.
The HDDS program helps provide compliant disposal for pharmaceutical waste, which includes Rx items that cannot be used for their intended purpose and which therefore must be disposed of.
Skilled nursing or LTCF staff should be trained to identify which medications can be returned for credit and which cannot per the acceptance protocols of their returns processor or reverse distributor.
Items without creditable value should be managed as Rx waste through the HDDS program. (Note: the HDDS program does not include DEA controlled substances or narcotics.)
2. Train staff to identify P-listed hazardous waste – warfarin and nicotine – and handle the packaging appropriately.
Warfarin and nicotine products are common in a long-term care setting. Because they fall into a special regulatory category called “acutely hazardous” or “P-listed” waste, these two items are subject to special regulations.
One key aspect of these regulations is that facilities must collect the packaging of warfarin and nicotine as P-listed hazardous waste. The other is that facilities must always have less than 2.2 pounds of warfarin and nicotine waste on-site at any given time.
In order to ensure that the amount of P-listed waste on-site is consistently tracked and documented, many LTCFs collect P-listed packaging separately from actual P-listed medications. Waste warfarin tablets or unused nicotine patches are generally produced in low volume and can be collected in a small 1.5 quart container. Empty packaging such as wrappers, bottles and bubblecards/blister packs, however, may require a larger 2 gallon container to accommodate bulk, even though empty packaging is generally very light and contributes little weight to the overall amount of P-listed waste generated.
Collecting and segregating P-listed waste in this fashion allows for consistent and accurate volume tracking.
3. Make it convenient: Place multiple Rx waste containers throughout the facility in easily accessible areas.
A successful Rx waste program is SAFE, SIMPLE, and COMPLIANT. This means that staff should be able to easily access an appropriate container from any point within the facility where Rx waste may be generated. If the placement of Rx waste containers requires staff to make a special trip to a remote area such as the basement or boiler room, they will be less likely to manage Rx waste correctly. Conversely, if Rx containers are staged on each floor or in each wing at a common area such as a med room or a nurse’s station, it is much easier to seamlessly integrate an Rx waste program into staff’s existing routines.
Stericycle’s Hazardous Drug Disposal Service provides a streamlined and RCRA-compliant approach to handling pharmaceutical waste generated in a non-acute healthcare setting. By federal law, DEA-controlled substances must be disposed separately.