1. The container utilized to store hazardous waste should be labeled "Hazardous Waste". 2. All containers which store hazardous waste should be closed except for when the container is being filled or emptied. 3. All containers which store hazardous waste should be inspected weekly for leaks or “lost” medications. 4. Use a hazardous waste manifest to “ensure proper disposal” as your documentation. 5. The facility should provide hazardous waste training to a point person as well as a backup person.

1. Anything that requires disposal. Ask yourself the question – “is this a hazardous waste when I need to dispose of it”? 2. Place the medication to be disposed in the proper container which should be labeled “hazardous waste”. 3. List the medication on a log sheet. 4. On a monthly basis weigh the container and keep a record of your monthly weights on a log. 5. Ensure proper disposal with a hazardous waste transport and disposal company.

NON P-LISTED HAZARDOUS WASTE GENERATION RATE TRACKING LOG NAME OF WASTE MEDICATIONDATE PLACED INTO CONTAINERMONTHLY WEIGHTCumulative Weight aldrin 1/15/2015 propanenitrile 1/31/2015 total1 pound aldrin 2/11/2015 propanenitrile 2/28/2015 total2.5 pounds 3.5 pounds aldrin 3/12/2015 propanenitrile 3/25/2015 total1.5 pounds 5 pounds

P-LISTED HAZARDOUS WASTE GENERATION RATE TRACKING LOG NAME OF WASTE MEDICATIONDATE PLACED INTO CONTAINERMONTHLY WEIGHTCumulative Weight warfarin 1/15/2015 nicotin 1/31/2015 total0.1 pound warfarin 2/11/2015 nicotin 2/28/2015 total0.5 pounds 0.6 pounds warfarin 3/12/2015 nicotin 3/25/2015 total1.0 pounds 1.6 pounds

 Inspections vs. responding to a complaint.  One day advance notice – schedule the inspection  Perform the inspection at your facility with a knowledgeable staff member regarding your waste management process and practices  Inspection typically starts with a meeting followed by visual verification.  Closing meeting and paperwork.

One Day Advance Notice (except complaints) a. Why only one day notice? b. What do I need to prepare for the inspection? c. Can we do it later? d. What if I’m not prepared?

The Day of the Inspection a. Inspections typically take 1-2 hours b. Opening meeting/discussion c. Visual inspection of hazardous waste storage areas d. Review hazardous waste determinations e. Review disposal documents f. paperwork, discussion, questions

Post Inspection - Violations During the inspection we will discuss any violations. At the end of the inspection, we’ll review the results and generate a “Compliance Advisory”, if any violations occurred. We will discuss the violations with you as well as what is expected including timeframes. You will be required to respond in writing by a deadline.

 Unaware of what is and isn’t a waste  No hazardous waste determinations  Sending medications down drain  Placing medications into trash (e.g. misuse of drug disposal technology)

Post Inspection – What about financial penalties? Compliance Advisory to Compliance Conference What happens at and after a compliance conference?

Post Inspection – NO Violations

If you store chemicals or pharmaceuticals onsite we will inspect those storage areas for expired or otherwise unusable chemicals and/or pharmaceuticals.

Its’ not uncommon to find outdated, expired, or otherwise unusual or unwanted materials which can lead to a violation for “lack of hazardous waste determination”.

This is a common sight. What is the violation here? Why? What should be done and when?

This is also a common sight. What is the violation here? Why? What should be done and when?

Might be hard to see but there are pharmaceuticals located in this sharps container. What is the violation?

What’s wrong with this picture?

A dedicated bin for infectious hazardous waste including a label indicating what can and cannot go into this bin. In addition to training, this is a best management practice to ensure proper disposal and avoid the memory game.

What’s good and bad about this container for the management of p-listed waste?

What’s the violation? Why?

Proper storage for waste bulbs. Notice the bulbs are fully contained, the box is closed and secure, the box is labeled.