1. Edith Nourse Rogers Memorial Veterans Hospital
PHARMACEUTICAL
HAZARDOUS
WASTE
MANAGEMENT
Edith Nourse Rogers Memorial Veterans Hospital

2. Environmental Regulations
Certain Pharmaceutical wastes generated in Patient Care areas and in the Pharmacy are considered “Hazardous Wastes” by both the:
U.S. Environmental Protection Agency (EPA)
Massachusetts Department of Environmental Protection (MA DEP)
Over the past several years, the proper management of waste Pharmaceuticals meeting the definition of a “Hazardous Waste” has been scrutinized at healthcare facilities

3. Inspections / Penalties
Both the EPA and the MA DEP may perform an unannounced random inspection of the hospital
Strict penalties can be imposed upon hospitals in violation of the Hazardous Waste regulations – up to $37,500 per violation, per day

4. What is a Hazardous Waste?
“Hazardous Waste” is an EPA term used to describe a waste, other than a nuclear waste, that is considered by EPA or a state environmental authority to either:
Cause or contribute to an increase in mortality or an increase in irreversible or incapacitating reversible illness; or
Pose a threat to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise mismanaged

5. Proper Waste Determination
By Federal and State regulation, hospitals are responsible for determining which Pharmaceuticals are considered Hazardous Wastes
Pharmaceuticals could be considered Hazardous Waste for several reasons, including:
The Pharmaceutical possesses a hazardous property, {i.e. it may be ignitable, reactive, corrosive, and/or toxic}
The Pharmaceutical is specifically listed by the Federal or State government as a hazardous compound, {i.e. Nicotine and Warfarin are both acutely toxic compounds}
The Pharmaceutical contains a heavy metal which is considered to be toxic in the environment. {i.e. Silvadine Cream (containing Silver) or Gramicidin (containing Mercury)} ?

6. Proper Waste Determination
Pharmaceutical waste comes in many different forms. Waste could be:
Unused, but not wanted product
Expired product
Product not fully administered to a patient
Packaging once in contact with product that may contain residue
Bedford VAMC collects:
All Hazardous Pharmaceutical Waste listed within the Pharmacy formulary
All bulk Chemotherapy
*No Controlled Substances (CS) Waste should be placed in the Pharmaceutical Hazardous Waste containers. There are CS Waste containers
specifically labeled to dispose of CS Waste located within
the Pharmacy and Patient Care areas near the Omnicell units.

7. Satellite Accumulation Area (SAA)
Bedford VAMC collects Pharmaceutical Hazardous Waste at a location called the Satellite Accumulation Area (SAA)
The purpose of the Satellite Accumulation Area (SAA) is to have a means by which Hazardous Waste (HW) generators may accumulate HW without an accumulation time limit as the containers slowly fill
SAAs are located throughout the campus - within each Patient Care area and Pharmacy. SAAs are located at Nurses’ Stations, in Medication Rooms, and within the Med-Carts

8. SAA Collection Containers
SAA containers are individual collection containers located on each Patient Care Unit and in the Pharmacy. By definition, they must be at or near the point of generation of the waste being collected.
SAA container collection areas on each Patient Care Unit have been identified and are located either in the Medication Room, the Med-Cart drawer, or at the Nurses’ Station
To have a full Pharmaceutical Hazardous Waste container removed, please contact the GEMS Coordinator at X2222 to arrange for a container change out
When full, the SAA containers are moved to the central Hazardous Waste collection center referred to as the Main Accumulation Area (MAA). The waste may remain on-site for up to 180 days prior to shipment off site.

9. SAA Pharmaceutical Hazardous Waste Containers
18 Gallon Yellow-labeled
2 Gallon
Yellow or Green-labeled
1.5 Quart Green-labeled

10. SAA Pharmaceutical Hazardous Waste Containers
500 mL Yellow & Green-labeled Pharmaceutical Hazardous Waste containers
Located within each Med-Cart

11. SAA Pharmaceutical Hazardous Waste Container Labels
The Green-labeled Pharmaceutical Hazardous Waste containers are for the collection of acutely toxic Pharmaceuticals not completely administers to a patient or product not spent for its intended purpose, and therefore, must be collected separately in its own waste stream.
This includes unused/expired Warfarin, Warfarin blister packs, Warfarin bags, empty Warfarin bottles, Nicotine gum, Nicotine gum blister packs, Nicotine lozenges, Nicotine lozenge Poppacs and blister packs, Nicotine patch adhesive backings and wrappers, and unused/expired Nicotine patches.
*If Nicotine or Warfarin has had contact with the patient, it is considered used for its intended purpose and does not need to be collected as Pharmaceutical Hazardous Waste.

12. SAA Pharmaceutical Hazardous Waste Container Labels
The Yellow-labeled Pharmaceutical Hazardous Waste containers are for the collection of products that have a certain hazardous characteristic, and that is not completely administers to a patient or product not spent for its intended purpose.
The Red-labeled Pharmaceutical Hazardous Waste containers are only located in the Pharmacy and in Urgent Care. Theses are the locations this waste would normally be generated.

13. SAA Pharmaceutical Hazardous Waste Container Labels
The Blue and Purple-labeled Pharmaceutical Hazardous Wastes are rare, but are still listed within the Pharmacy’s formulary. These containers would be located only in the Pharmacy.

14. Additional SAA Pharmaceutical Hazardous Waste
The Red-labeled Pharmaceutical Hazardous Waste (Unused and expired Silver Nitrate sticks) must be returned to the Pharmacy for collection and cannot be disposed of on the Patient Care Units. Urgent Care is the only other unit that has a Red-labeled container.
Aerosolized inhalers must be returned to the Pharmacy
for collection.

15. Additional Pertinent Information
Unless otherwise stated:
All non-hazardous, unwanted or expired medications that cannot be returned back to the Pharmacy through the Pharmacy Reverse Distribution program and that are not listed as Pharmaceutical Hazardous Wastes or as
CS Wastes can be disposed of into the 18 Gallon Yellow-labeled Pharmaceutical Hazardous Waste containers.
Also, all non-hazardous empty or unwanted creams, lotions, gels, liquids, toothpaste tubes, etc. can be disposed of in the 18 Gallon Yellow-labeled Pharmaceutical Hazardous Waste containers.
Why?
Because it diverts these non-hazardous products and medications from ending up in landfills and from going into the sanitary wastewater system.
THINK GREEN

16. SAA Container Management & Weekly Inspections
By regulations, all Satellite Accumulation Area Pharmaceutical Hazardous Waste collection containers must be inspected Weekly by the generator of such waste. However, there is no documentation required.
What to look for during visual weekly inspection of containers at each SAA:
Container must remain closed when not in use
Container must be compatible with its contents
Container must be kept unobstructed (>36” on labeled side)
Container must not be managed in a manner to cause a leak or rupture
Container must be labeled with the words, “HAZARDOUS WASTE”
Container must be labeled with a listing of the contained drug wastes
Container must be labeled with a hazard classification
Contact the GEMS Coordinator at X2222 to schedule a Pharmaceutical Hazardous Waste container change out or if a container does not comply with the inspection requirements
*Do not start a new container until the full container has been removed.

17. Chemotherapy Collection
With the implementation of the Pharmaceutical Hazardous Waste program there are minor changes to the Chemotherapy collection process
Yellow Chemotherapy Containers will be collecting:
Personal Protective Equipment that has come into contact with Chemotherapy substances
Empty Chemotherapy IV bags (containing trace Chemotherapy: ≤ 3%) and associated IV tubing
Black Hazardous Waste Containers (18 Gallon Yellow-labeled) located in the Patient Care Units will be collecting:
All Chemotherapy IV bags and associated IV tubing of bulk amounts (bulk amounts: ≥ 3%) must be collected in this container

18. Pharmaceutical Hazardous Waste References
Hazardous Pharmaceutical Waste Collection Policy and associated Appendices – Bedford VAMC Memoranda
Bedford VAMC GEMS Coordinator – (781)
Bedford VAMC Safety Office – (781) /2714
Massachusetts Code of Regulations:
310 CMR

19. Pharmaceutical Hazardous Waste Knowledge Review
Question #1:
What agencies regulate Pharmaceutical Hazardous Wastes?
NRC
EPA
OSHA
MA DEP
Both b and d

20. Pharmaceutical Hazardous Waste Knowledge Review
Question #2:
An SAA container of Pharmaceutical Hazardous Waste must be …?
Labeled with the words, “HAZARDOUS WASTE”
Closed when not in use
Labeled with a listing of the contained drug wastes
Labeled with a hazard classification
All of the above

21. Pharmaceutical Hazardous Waste Knowledge Review
Question #3:
Why would a Pharmaceutical product be regulated as a Hazardous Waste?
It may possess a hazardous property (i.e. ignitable, corrosive)
It may be listed as a hazardous chemical compound (i.e. Nicotine, Warfarin)
It may contain a certain heavy metal that is toxic in the environment (i.e. Mercury, Silver)
It may pose a threat to human health or to the environment
All of the above

22. Pharmaceutical Hazardous Waste Knowledge Review
Question #4:
A Pharmaceutical Hazardous Waste could be …?
Packaging with a residue once in contact with a Green-labeled product (i.e. Nicotine patch adhesive backing)
Unused, but not wanted
An expired product
A product not fully administered to a patient (i.e. a pill fell onto the floor before entering the patient’s mouth)
All of the above

23. Pharmaceutical Hazardous Waste Knowledge Review
Question #5:
True or False
When any Patient Care area or Med-Cart Pharmaceutical Hazardous Waste container is full, you should contact the GEMS Coordinator at X2222 for a waste container change out.