1. Pharmaceutical Waste Disposal at the University of Washington Matt Moeller, CHMM

2. University of Washington (UW) Profile  Three campuses, two academic medical centers, numerous clinics and offsite research facilities.  $1.4 Billion in total grants and contracts for FY 2013 –Largest research volume for public higher education  1.7 Million square feet of lab space and 4,000 labs  51,500 students  4,300 faculty and almost 30,000 staff –3 rd largest non-federal employer in Washington State.

3. Our “growing” problem of pharmaceutical waste disposal  Dramatic increase in waste volume…

4. Our “growing” problem of pharmaceutical waste disposal, part 2  Increased volumes at our offsite locations also

5. The issues  Increased disposal cost (currently $2.23/kg)  Increased volume = increased workload  Training  Impact on Generator status  what to do with DEA regulated materials –Onsite destruction issue  Use of Washington State Pharmacy Rule?

6. The Process  First step is designation –Formularies –RCRA vs State Regulated Only –DEA scheduled pharmaceuticals –Generator status –RMW  Second step is determining best packaging options  Third step is training in segregation and use of the various packaging options

7. Designation  Done by a review of a sites formulary…

8. Generator Status  Washington State has its own Department of Ecology –They have 3 types of generators  SQG = less than 2.2 lbs of acutely hazardous waste (AHW) or extremely hazardous waste (EHW, specifically WT01 waste code) and less than 220lbs of dangerous waste (DW).  MQG –220 lbs to 2200 lbs DW.  LQG – more than 2200 lbs DW or more than 2.2 lbs of AHW or WT01.

9. Then determine if there will be a “mixed waste” issue  Will they be generating a mixed waste?

10. “Empty” Containers… What does it mean  Most potential mixed waste issues will be “empty” containers

11. EHW & P Listed empty containers  We manage those as hazardous waste

12. Containers  It wasn’t easy at first to find non-biohazard marked sharps containers…

13. Waste Profile  At first we separated EHW and DW waste streams and Chemo  Then worked with our vendor to combine all waste streams into one profile with variable codes

14. EPA is still developing a proposed new rule to address the management of pharmaceuticals…

15. Washington State Department of Ecology  They have 3 options for how you can handle your Pharmaceutical waste disposal.

16. Washington State Department of Ecology Continued…  You can manage state only dangerous waste under the “Conditional Exclusion for Pharmaceutical Waste” (WAC 173-303-071(3)(nn))  You can use the “Interim Enforcement Policy for Pharmaceutical Waste” (Ecology publication #07-04- 024)  Or you can just manage it like any RCRA hazardous waste

17. That means you have to segregate it out from the rest But while those are some good advantages, there are disadvantages that lead us not to use this Policy. Our LQGs would still be LQGs, and amount of EHW @ SQGs = SQG

18. Segregation of Pharmaceuticals at SQGs  We provide them with a short simple “cheat sheet” list of types of drugs we need to know if they will have for disposal.

19. Segregation at the UWMC  Segregation here is based on the type of waste

20. Segregation at HMC  Different hospital, a different approach

21. Training  We provide guidance and help in developing training materials for the various staff involved with this waste stream > This is an example of a flow chart we made to help one location train their staff

22. Training Example  This is an example of what HMC developed for their staff

23. Training Example Continued  There test is a “drag and drop” one…

24. Can you help…  Our biggest unresolved issue is to find an onsite destruction method for our DEA regulated pharmaceuticals that our waste contract will accept.  New Final Rule allows for “non-retrievable” drugs to be considered no longer DEA regulated.  Do you have something that works?

25. The End…  Any questions?