CHAD FISHER HAZARDOUS WASTE COMPLIANCE INSPECTOR WA STATE DEPARTMENT OF ECOLOGY AUGUST 30, 2013 Managing Pharmaceutical Waste in Washington State

Overview for Today Dangerous waste management overview Options for managing pharmaceutical waste History of Ecology’s work on pharmaceutical waste Challenges (violations) we’re seeing with generators of pharmaceutical waste during dangerous waste inspections

Dangerous Waste Management Overview Must designate waste  WAC through -100, -170 Notification – based on generator status  WAC , -170, -070(8) Annual reporting – based on generator status  WAC , -390, -070(8) On-site management – based on generator status  WAC , -201,-202, -320, -630, -640, -070(8) Manifest waste – based on generator status  WAC , -070(8)  Guide for Dangerous Waste Generators in WA State – Pub#

Dangerous Waste Regulations Interim Enforcement Policy (IEP) Chapter WAC Conditional exclusion  WAC (3)(nn) Enforcement discretion policy  Publication # Conditional exclusion  WAC (3)(nn) /pharmaceuticals/index.html Options for Managing Pharmaceutical Waste

Dangerous Waste Regulations Interim Enforcement Policy Must designate pharmaceutical waste Must count & report all DW pharmaceutical waste  Counts towards generator status TurboWaste reporting based on facility generator status May utilize conditional exclusion Must designate pharmaceutical waste No count or report for pharmaceutical waste  Does not count towards generator status Must submit profile and notification  TurboWaste reporting continues for remainder of facility May utilize conditional exclusion Pharmaceutical Waste Management

History: Ecology’s work on pharmaceutical waste Memorandum Of Understanding with WA State Hospital Association in 2005: technical assistance focus Generator inspections including pharmaceutical waste began in approximately 2011 Ecology continues to work with both generators and transporters of pharmaceutical waste: both compliance inspections and technical assistance

Recent inspection findings: general principles Training  On site contact and/or staff not familiar with pharmaceutical waste program Improper segregation of dangerous waste pharmaceuticals  Non-empty vials/syringes disposed in sharps, Regulated Medical Waste, or garbage containers Container management  Labeling and/or accumulation requirements not met If using IEP, notification and profile not submitted to Ecology  Without notification, the Policy’s enforcement discretion not possible

Recent compliance inspection findings: specifics Scope: Within Ecology’s Northwest Region (King, Snohomish, Skagit, Whatcom, Kitsap and Island Counties), September 2011 to present. # of visits: 18 # of inspections: 17 # of technical assistance visits: 1 Of total facilities, # using IEP: 11 Of total facilities, # not using IEP: 6

Recent compliance inspection findings: specifics Improper segregation of dangerous waste pharmaceuticals: non-empty vials/syringes disposed in sharps, regulated medical waste, or garbage containers (improper disposal) # of visits resulting in a violation: 10 # of visits resulting in a “concern”: 5 # of visits resulting in no violation or “concern”: 3 New publication: “Focus On Dangerous Waste: Handle Pharmaceutical Waste Properly” html

Example: pharmaceutical waste in garbage

Example: pharmaceutical waste in sharps

Recent compliance inspection findings: specifics Container management: labeling and/or accumulation requirements not met  Examples: hazardous waste/dangerous waste label, risk label, accumulation start date (if applicable), closed container # of visits resulting in a violation: 15 # of visits resulting in a “concern”: 1 # of visits resulting in no violation or “concern”: 2  In both cases there were other problems with managing pharmaceutical waste

Context: Current and Future Ecology understands that pharmaceutical waste management is a significant challenge for healthcare facilities. Ecology expects generators to continue to move forward with implementation of a compliant pharmaceutical waste management program. In addition to regular compliance inspections, Ecology provides:  technical assistance through the compliance program  technical assistance through the Pollution Prevention Planning Program The Interim Enforcement Policy for Pharmaceutical Waste is still … an interim policy. Changes in WA State pharmaceutical waste regulations are not likely until after EPA’s rule is final.  EPA is planning to have a draft pharmaceutical waste rule in 2014.

Pharmaceutical Waste Management Northwest Region Technical assistance  Jenny Yoo   Compliance assistance  Chad Fisher    Trudy Harding   Central Region Technical assistance  Holly Cushman   Compliance assistance  Amy Cook   Southwest Region Technical assistance  Leatta Dahlhoff   Compliance assistance  Lisa Perle   Eastern Region Compliance assistance  Lori Rodriguez   Statewide Questions – Ecology HQ  Tom Cusack  