Ensure compliance with EPA rule: Ban all sewering of hazardous waste drugs
By A.J. Plunkett (email@example.com)
The August 21 ban on the sewering of hazardous waste pharmaceuticals is the first deadline set out in new regulations published by the EPA in February that sets up a new category, Subpart P, under the federal Resource Conservation and Recovery Act (RCRA).
Review and update your policies on the disposal of pharmaceuticals to prohibit the flushing of any drugs into the sewers. Experts say that may be the best way to ensure compliance with the new EPA regulation. In addition, it will help ease requirements on front-line staffers who will no longer have to keep track of what they can and can’t flush down the drain.
And it may even help you stay on the good side of federal regulators who are encouraging the no-sewering of any drug as a best practice to protect water resources.
The ban is the only part of the rule that goes into effect at all healthcare facilities across the United States and its territories, without exception. That’s because the EPA is declaring the ban under the authority set out by the federal Hazardous and Solid Waste Amendments (HSWA).
Other parts of the final rule, officially known as the “Management Standards for Hazardous Waste Pharmaceuticals & Amendment to the P075 Listing for Nicotine,” are under RCRA and must be approved in each state or territory that has its own RCRA-authorized program (more on that in a bit.)
The sewering ban is also one of the more stringent changes outlined in the rule. And the EPA only has the authority to ban flushing of those drugs deemed to be hazardous waste as outlined under RCRA regulation, notes Wade Scheel, Director of Governmental Affairs for Stericycle Environmental Solutions.
However, in the preamble to the final rule the EPA “clearly makes it known” its position on sewering of all drugs, he says.
That preamble states: “We note that although our RCRA statutory authority limits us to apply the prohibition on sewering narrowly to pharmaceuticals that are RCRA hazardous wastes, EPA strongly recommends as a best management practice to not sewer any waste pharmaceutical (i.e., hazardous or non-hazardous) from any source or location.”
The EPA even goes on to ask households to do the same.
The concern is that public sewer and water systems were not designed to filter out what has become very complex chemical and biological elements found in many drugs—even if they’re not technically considered hazardous waste, says Scheel.
Pharmaceuticals can have a significant impact on the environment, according to Michael Ganio, Pharm.D., M.S., BCPS, FASHP, director of Pharmacy Practice and Quality with the American Society of Health-System Pharmacists (AHSP.)
“Studies have shown that non hazardous-waste drugs that are disposed of down the drain can be found in water supplies and in lakes and streams, so a best practice is not to dispose of any pharmaceuticals down the drain,” says Ganio.