Colorado Department of Public Health and the Environment Frequently Asked Questions Daniel Goetz – CDPHE Tom Fawks – Consultant Pharmacist

Online Resources? CDPHE Medical and Pharmaceutical Waste Guidance Documents can be found here: medical-and-pharmaceutical-waste- guidance

Have Questions? Hazardous Waste Contact Dan Goetz: Sharps, Biohazardous, Medical Waste (non RCRA waste) Contact Jace Driver: Household Medical Waste Contact Greg Fabasiak:

Regulatory Updates 1.DEA regulatory update (Sept 2014) 2.EPA regulatory update (2015) 3.Health Facilities regulatory update (2016)

Highlights from 2015: 279,000 units of medicine donated, valued at over $120,000 (NADAC). Retail price would be valued at 3x that number. We were able to transfer 58,000 units worth $13,500 to a network of free and charitable providers. Highlights of 2016 through late March: 102,000 units of medicine worth $55,000. Transfers 19,000 units of medicine to a network of 6 clinics worth over $11,000.

Interested in learning more medicine donation? Is there a local charitable clinic you think would be interested in receiving donated medicine? Contact: Kiah Williams, Director office sirum.org

Hazardous Medication Disposal Questions encountered by a consultant pharmacist Tom Simpleman Consultant Pharmacist RPh, CGP, FASCP, CPHQ

Disposal of solutions How do I dispose of Intravenous solutions or Irrigation Solutions? i.e. Normal Saline, D5W, Lactated Ringers

Commercially Available Disposal Systems Can we really just throw it away in normal trash?

Commercially Available Disposal Systems Cactus sink Drug Buster Rx Destroyer Medsaway C2R

Commercially Available Disposal Systems Dispose of it in regular trash?

Disposal of an open vial 10 ml vial of insulin Use 0.5 mg Meets the BUD (beyond use) date to discard How do I dispose of the remainder? Why is Insulin a RCRA drug?

Disposal of an open vial I changed from 2 ml vials to 1 ml syringes of Mitomycin ophthalmic, I use less than the full syringe. How do I dispose of the remainder and syringe

ASC location ASC located adjacent to a hospital building. Can we use their medication disposal system? Are we responsible for maintaining records of how the medical wasted is disposed? If so, what records are we responsible for keeping and how long?

Medication Disposal Companies How can I find medication disposal companies? Are they expensive?

Companies that do not respond Contacted Steri-Cycle – Get run around to find contact – They promise someone will call back – Don’t receive call – Contacted, promised a representative would stop by the next week – Never stopped or returned call What are my responsibilities in this situation?

How much? Where did the 2.2 pounds come from? How frequently do I need to send it to the disposal company? Do I need to inspect the containers they are stored in regularly? Can I return the RCRA waste to a pharmacy and not have to track it?

Tracking What documentation is needed? Is simply stating I sent it to Stericycle enough? Why do I have to keep this documentation? Is it OK if only one person does everything?

Training What education is required? How many should be trained? Should responsibilities be assigned? – If so which ones? What about non-RCRA meds such as antibiotics?

Question: How can I ensure I am protected from liability once the hazardous waste leaves my facility?

Answer A CESQG is required to ensure that their hazardous waste is delivered to a permitted hazardous waste treatment, storage or disposal facility (TSD). Although CESQGs are not required to use a hazardous waste manifest to ship hazardous medication waste, this would be the best method to ensure that your hazardous medication waste was properly disposed. The TSD is required to send a signed copy of the manifest back to the generator. For hazardous medication waste that is sent to a reverse distributor, the Department accepts that a statement from the reverse distributor, on a contract or invoice, that they properly dispose of all hazardous medication wastes at a permitted TSD as proof that the generator has met the CESQG requirement. However, this is not a guarantee that you are immune from liability if the reverse distributor fails to properly dispose of the waste.

What about epinephrine salts or nitroglycerin? Epinephrine salts are not P042 hazardous waste in Colorado. Medicinal nitroglycerin is generally not reactive (i.e.,not P081 hazardous waste) but 5mg/ml concentration may be ignitable (D001).

QUESTIONS?