Pharmaceutical Waste Pharmaceutical Waste Management & Management & Minimization Minimization

Janet Bowen, EPAJanet Bowen, EPAMarch 26, 2008March 26, 2008

Overview of PresentationOverview of Presentation

• Environmental impacts of prescription drugs Environmental impacts of prescription drugs • Review of 10-Step Blueprint including Regulatory Review of 10-Step Blueprint including Regulatory

RequirementsRequirements• Federal role: White House disposal guidelines, Federal role: White House disposal guidelines,

research, & policy implicationsresearch, & policy implications• Stewardship activities – state programsStewardship activities – state programs• Region II enforcement summaryRegion II enforcement summary• Additional ProgramsAdditional Programs

11stst National Study Revealed Extent of National Study Revealed Extent of Pharms in WaterwaysPharms in Waterways

• USGS “Reconnaissance” study in 1999-2000 was USGS “Reconnaissance” study in 1999-2000 was 11stst nationwide investigation of pharms, hormones, nationwide investigation of pharms, hormones, & other organic contaminants in 139 streams in 30 & other organic contaminants in 139 streams in 30 states:states:– 82 of 95 antibiotics, prescription & non-prescrip drugs, 82 of 95 antibiotics, prescription & non-prescrip drugs,

steroids, & hormones were found in at least 1 samplesteroids, & hormones were found in at least 1 sample– 80% streams had 1 or more contaminant80% streams had 1 or more contaminant– 75% streams contained 2 or more75% streams contained 2 or more– 54% had more than 554% had more than 5– 34% had more than 1034% had more than 10– 13% tested positive for more than 20 targeted contaminants13% tested positive for more than 20 targeted contaminants

National & International Studies Have National & International Studies Have Shown…Shown…

• Male fish, alligators, frogs, & other species with female organs & Male fish, alligators, frogs, & other species with female organs & eggseggs

• Declines in human sperm counts, rise in female infertilityDeclines in human sperm counts, rise in female infertility• Pharm compounds found at wastewater treatment plantsPharm compounds found at wastewater treatment plants• Anti-cholesterol drug nearly killed test fishAnti-cholesterol drug nearly killed test fish• Cocktail of 13 drugs inhibited kidney cell growthCocktail of 13 drugs inhibited kidney cell growth• Prozac linked to premature release of mussel larvaeProzac linked to premature release of mussel larvae• Associated Press Probe finds drugs in drinking waterAssociated Press Probe finds drugs in drinking water

• National Pharm Listserve National Pharm Listserve http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwastehttp://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste

How Pharmaceuticals enter the How Pharmaceuticals enter the EnvironmentEnvironment

Two RoutesTwo Routes

• Excretion of unmetabolized medicationsExcretion of unmetabolized medications• Waste of unused medicationsWaste of unused medications

PURPOSEFULPURPOSEFUL INADVERTENTINADVERTENT

Why Can’t We Take the PPCPs out of the Why Can’t We Take the PPCPs out of the Water?Water?

• POTWs are not designed to remove PPCPsPOTWs are not designed to remove PPCPs• Promising technologies include:Promising technologies include:

– OxidationOxidation– OzonationOzonation– UltrasoundUltrasound– Activated carbonActivated carbon– Reverse osmosisReverse osmosis

• Longer retention times (POTWs with nutrient removal) Longer retention times (POTWs with nutrient removal) look promisinglook promising

• Focus on controlling disposal at sourceFocus on controlling disposal at source

Managing Pharmaceutical Waste:10 Managing Pharmaceutical Waste:10 Step Blueprint for Health Care Step Blueprint for Health Care

FacilitiesFacilities

Introduction to a pharmaceutical waste Introduction to a pharmaceutical waste management tool – use it to implement management tool – use it to implement a pharmaceutical waste management a pharmaceutical waste management

system!system!http://www.h2e-online.org/docs/http://www.h2e-online.org/docs/h2epharmablueprint41506.pdfh2epharmablueprint41506.pdf

Review of the 10 StepsReview of the 10 Steps

Step 1Step 1 Getting Started Getting Started– Support from Senior ManagementSupport from Senior Management– Develop a CommitteeDevelop a Committee– Plan for opportunities, challenges and Plan for opportunities, challenges and

financial implications to making changes, financial implications to making changes, improvements in your facility.improvements in your facility.

Step 2: Understanding the RegulationsStep 2: Understanding the RegulationsHazardous Waste BackgroundHazardous Waste Background

What is Hazardous Waste: What is Hazardous Waste: • Waste that is dangerous or potentially harmful to Waste that is dangerous or potentially harmful to

human health or the environmenthuman health or the environment• Can be liquids, solids, contained gases, or sludgesCan be liquids, solids, contained gases, or sludges

Hazardous waste is regulated under the Resource Hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA):Conservation and Recovery Act (RCRA):• Appears on one of the four hazardous wastes lists Appears on one of the four hazardous wastes lists

(P-list, U-list, F-list, or K-list)(P-list, U-list, F-list, or K-list)• Or exhibits at least one of four characteristics Or exhibits at least one of four characteristics

(Ignitability, Corrosivity, Reactivity, or Toxicity)(Ignitability, Corrosivity, Reactivity, or Toxicity)

Hazardous Waste BackgroundHazardous Waste Background

• In all states, the Environmental Department is the agency In all states, the Environmental Department is the agency authorized to regulate hazardous waste under RCRAauthorized to regulate hazardous waste under RCRA  

• A discarded pharmaceutical may be identified as a A discarded pharmaceutical may be identified as a hazardous waste if it appears on a regulatory list of hazardous waste if it appears on a regulatory list of hazardous wastes (P or U) or exhibits one of four hazardous wastes (P or U) or exhibits one of four hazardous characteristics (ignitability, corrosivity, hazardous characteristics (ignitability, corrosivity, reactivity or toxicity)reactivity or toxicity)

Healthcare Environmental Resource CenterHealthcare Environmental Resource Center

www.hercenter.orgwww.hercenter.org

Step 2Step 2 Understanding the Regulations Understanding the Regulations P-Listed WastesP-Listed Wastes

•P-Listed Wastes P-Listed Wastes – Sole active ingredient Sole active ingredient – Unused – drug has not been given to a patientUnused – drug has not been given to a patient

•Empty ContainersEmpty Containers– Empty if triple rinsedEmpty if triple rinsed– Rinsate must be managed as hazardous wasteRinsate must be managed as hazardous waste– Rinsing generally not practical for pharmaceutical Rinsing generally not practical for pharmaceutical

wastewaste

Hazardous Waste: Listed Hazardous Waste: Listed

If the pharmaceuticals you are using appears on these If the pharmaceuticals you are using appears on these lists, the waste must be handled as a hazardous wastelists, the waste must be handled as a hazardous waste

Common P-Listed Pharmaceuticals:Common P-Listed Pharmaceuticals:

• Please note that Please note that this list is not intended to be completethis list is not intended to be complete. The . The full list of all P-listed wastes appear in the Code of Federal full list of all P-listed wastes appear in the Code of Federal Regulations, 40 CFR 261.33. Regulations, 40 CFR 261.33.

Arsenic trioxide P012

Epinephrine P042

Nicotine P075

Nitroglycerin P081

Physostigmine P204

Physostigmine salicylate P188

Warfarin >0.3% P001

Step 2Step 2 Understanding the Regulations Understanding the Regulations Regulatory Interpretation: Regulatory Interpretation:

Epinephrine SaltsEpinephrine Salts

• October 15, 2007 EPA MemoOctober 15, 2007 EPA Memohttp://www.epa.gov/region1/healthcare/pdfs/EpiMemo_Final.pdfhttp://www.epa.gov/region1/healthcare/pdfs/EpiMemo_Final.pdf

• Epinephrine salts are not a P042 listed Epinephrine salts are not a P042 listed waste (federally)waste (federally)

• States are delegated the RCRA program States are delegated the RCRA program and can be more stringentand can be more stringent

Step 2Step 2 Understanding the Regulations Understanding the Regulations Nitroglycerin ExemptionNitroglycerin Exemption

• Medical nitroglycerin removed as a P-listed waste Medical nitroglycerin removed as a P-listed waste – Weak, non-reactive, formulationWeak, non-reactive, formulation

• Some formulations may fail ignitability characteristic Some formulations may fail ignitability characteristic – Waste injectables Waste injectables – AerosolsAerosols

• State may be more stringent (or may be still adopting the State may be more stringent (or may be still adopting the rule) – check with your state on their position on rule) – check with your state on their position on NitroglycerinNitroglycerin

Step 2Step 2 Understanding the Regulations Understanding the Regulations U-Listed WastesU-Listed Wastes

• U-listed Wastes U-listed Wastes – Sole active ingredientSole active ingredient– UnusedUnused

• Empty ContainersEmpty Containers– All contents have been removed that can be All contents have been removed that can be

removed through normal means and no more removed through normal means and no more than 3% by weight remains than 3% by weight remains

– Residues removed from container must be Residues removed from container must be managed as hazardous wastemanaged as hazardous waste

Hazardous Waste: Listed Hazardous Waste: Listed

Common U-Listed PharmaceuticalsCommon U-Listed Pharmaceuticals

• Please note that Please note that this list is not intended to be completethis list is not intended to be complete. The full list of all . The full list of all U-listed wastes appear in the Code of Federal Regulations, 40 CFR 261.33. U-listed wastes appear in the Code of Federal Regulations, 40 CFR 261.33.

Chloral Hydrate (CIV)2 U034 Mitomycin C (chemo) U010

Chlorambucil (chemo) U035 Paraldehyde (CIV)2 U182

Chloroform U044 Phenacetin U187

Cyclophosphamide (chemo)

U058 Phenol U188

Daunomycin (chemo) U059 Reserpine U200

Dichlorodifluromethane U075 Resorcinol U201

Diethylstilbestrol U089 Saccharin U202

Formaldehyde U122 Selenium sulfide U205

Hexachlorophene U132 Streptozotocin (chemo) U206

Lindane U129 Trichloromonofluromethane U121

Melphalan (chemo) U150 Uracil mustard (chemo) U237

Mercury U151 Warfarin <0.3% U248

Hazardous Waste: CharacteristicHazardous Waste: Characteristic

If the pharmaceuticals you are using exhibits one of If the pharmaceuticals you are using exhibits one of four hazardous characteristics, the waste must be four hazardous characteristics, the waste must be handled as a hazardous wastehandled as a hazardous waste

Ignitability - having a flash point less than 60Ignitability - having a flash point less than 60ooCC

• Ignitable Characteristic Pharmaceuticals:Ignitable Characteristic Pharmaceuticals: Any formulations with more than 24% alcohol Any formulations with more than 24% alcohol Oxidizers such as Potassium Permanganate and Oxidizers such as Potassium Permanganate and

Silver Nitrate Silver Nitrate CollodionCollodion

Corrosivity - having a pH less than 2 or greater than Corrosivity - having a pH less than 2 or greater than 12.512.5• Corrosive Characteristic Pharmaceuticals:Corrosive Characteristic Pharmaceuticals:

Compounding Agents such as Glacial acetic acid and Compounding Agents such as Glacial acetic acid and Sodium Hydroxide Sodium Hydroxide

Hazardous Waste: CharacteristicHazardous Waste: Characteristic Reactivity - liable to explode, or react violently or Reactivity - liable to explode, or react violently or

release toxic gases when in contact with water release toxic gases when in contact with water • Reactive Characteristic Pharmaceuticals:Reactive Characteristic Pharmaceuticals:

NitroglycerinNitroglycerin

Toxicity - containing a regulated substance at a Toxicity - containing a regulated substance at a concentration above the limit concentration above the limit • Toxic Characteristic Pharmaceuticals:Toxic Characteristic Pharmaceuticals:

Zinc (some shampoos)Zinc (some shampoos) SeleniumSelenium

How does this apply to Pharmacy?How does this apply to Pharmacy?

Facilities that generate hazardous waste Facilities that generate hazardous waste are regulated as one of the following:are regulated as one of the following:

• Conditionally Exempt Small Quantity Generators Conditionally Exempt Small Quantity Generators (CESQGs)(CESQGs) Generate less than 100 kg of hazardous waste Generate less than 100 kg of hazardous waste per calendar monthper calendar month* *

• Small Quantity Generators (SQGs)Small Quantity Generators (SQGs) Generate between 100 kg and 1000 kg of Generate between 100 kg and 1000 kg of hazardous waste per calendar monthhazardous waste per calendar month**

• Large Quantity Generators (LQGs)Large Quantity Generators (LQGs) Generate greater than 1000 kg of hazardous Generate greater than 1000 kg of hazardous waste per calendar monthwaste per calendar month

* * And no more than 1 kg (2.2 lbs) of acutely And no more than 1 kg (2.2 lbs) of acutely hazardous waste per calendar month counts hazardous waste per calendar month counts weight of containerweight of container

Step 3Step 3 Consider Best Management Consider Best Management Practices (BMPs) for Non-Regulated Practices (BMPs) for Non-Regulated Pharmaceutical WastesPharmaceutical Wastes– Recommendations made for how to manage Recommendations made for how to manage

pharmaceutical waste to protect water bodies, pharmaceutical waste to protect water bodies, aquatic species, human health.aquatic species, human health.

– Incineration (endocrine disruptors, carcinogenic Incineration (endocrine disruptors, carcinogenic drugs, Formulations w/listed active ingredient drugs, Formulations w/listed active ingredient that is not the sole active ingredient, etc.)that is not the sole active ingredient, etc.)

– Eliminate drain disposalEliminate drain disposal– Avoid LandfillingAvoid Landfilling– Use non PVC IV SetsUse non PVC IV Sets

Step 3Step 3 - BMPs - BMPs Managing to the Highest StandardManaging to the Highest Standard

• Hazardous waste regulations have not Hazardous waste regulations have not kept pace with drug development kept pace with drug development

• Approximately 10% of the drugs that are Approximately 10% of the drugs that are not regulated are equally as hazardous. not regulated are equally as hazardous.

• Best management practices encourage Best management practices encourage managing drugs that are equally harmful managing drugs that are equally harmful as hazardous waste when discardedas hazardous waste when discarded

Step 3Step 3 - BMPs - BMPs Dartmouth Hitchcock Medical Center Waste Dartmouth Hitchcock Medical Center Waste

Characterization SummaryCharacterization Summary

84%

11%

5%

FederallyHazardousBMPHazardous

NonHazardous

Step 3Step 3 - BMPs - BMPs Summary BMPsSummary BMPs

• Drugs with more than one active ingredientDrugs with more than one active ingredient• All chemotherapy drugsAll chemotherapy drugs• Drugs meeting OSHA and NIOSH criteriaDrugs meeting OSHA and NIOSH criteria• Drugs on:Drugs on:

– OSHA Technical Manual AppendixOSHA Technical Manual Appendix– DHHS list of carcinogensDHHS list of carcinogens

• Drugs with low oral LD 50sDrugs with low oral LD 50s• Endocrine disruptors Endocrine disruptors • Vitamin and mineral preparationsVitamin and mineral preparations• Contaminated PPE and spill clean Contaminated PPE and spill clean

up materialup material• Eliminate drain disposalEliminate drain disposal

Step 4Step 4 Perform Review of Drug Inventory Perform Review of Drug Inventory

• Obtain purchasing data from Drug Wholesaler Obtain purchasing data from Drug Wholesaler and/or purchasing recordsand/or purchasing records– Identify ingredientsIdentify ingredients– Determine RCRA hazardous waste codeDetermine RCRA hazardous waste code– Consider Compounded Items & ReformulationsConsider Compounded Items & Reformulations

• Gather Drug-Specific Data – national drug Gather Drug-Specific Data – national drug code, brand name, generic name, Mfr, strength, code, brand name, generic name, Mfr, strength, dosage form, package sizedosage form, package size

• Document decision making processDocument decision making process

• Keep the review currentKeep the review current

Step 5Step 5 Minimizing Pharmaceutical Waste Minimizing Pharmaceutical Waste 1.1. Consider lifecycle Impacts in Purchasing ProcessConsider lifecycle Impacts in Purchasing Process

– Longer expiration dateLonger expiration date• Some epinephrine products have longer shelf life than others to Some epinephrine products have longer shelf life than others to

minimize waste from crash carts and other areas where the minimize waste from crash carts and other areas where the drug is stored for emergencies drug is stored for emergencies

– Products with less packaging Products with less packaging • Packaging in contact with RCRA P-listed drugs must be Packaging in contact with RCRA P-listed drugs must be

managed as hazardous waste managed as hazardous waste

– Products without hazardous preservativesProducts without hazardous preservatives

2.2. Maximize Use of Opened Chemotherapy VialsMaximize Use of Opened Chemotherapy Vials3.3. Implement Samples PolicyImplement Samples Policy4.4. Labeling Drugs for Home UseLabeling Drugs for Home Use5.5. Priming & Flushing IV lines w/Saline SolutionPriming & Flushing IV lines w/Saline Solution6.6. Examine Size of Containers Relative to UseExamine Size of Containers Relative to Use

Step 5Step 5 Minimizing Pharmaceutical Waste Minimizing Pharmaceutical Waste (cont’d)(cont’d)

7.7. Replace Prepackaged Unit Dose Replace Prepackaged Unit Dose Liquids w/Patient-Specific Oral SyringesLiquids w/Patient-Specific Oral Syringes

8.8. Try to eliminate generation of controlled Try to eliminate generation of controlled substances that are also hazardous substances that are also hazardous wasteswastes

9.9. Use hard plastic buckets for delivery of Use hard plastic buckets for delivery of chemotherapy drugs to hospital floors – chemotherapy drugs to hospital floors – not brown paper bagsnot brown paper bags

10.10. Monitor dating on emergency syringesMonitor dating on emergency syringes11.11. Review inventory controls to Review inventory controls to

minimize outdatesminimize outdates

Step 5Step 5 Minimizing Pharmaceutical Minimizing Pharmaceutical WasteWaste (cont’d)(cont’d)

• Limitations on less hazardous drug Limitations on less hazardous drug substitutionsubstitution– Hazardous nature of drug often provides Hazardous nature of drug often provides

therapeutic effecttherapeutic effect• Always ask:Always ask:

– What pharmaceuticals are being wasted?What pharmaceuticals are being wasted?– Why are they being wasted?Why are they being wasted?– How can wasting be minimized?How can wasting be minimized?

Step 6Step 6 Assess Current Practices Assess Current Practices

–Conduct Department ReviewsConduct Department Reviews

–Conduct Analyses FrequentlyConduct Analyses Frequently

–Confirm your Generator StatusConfirm your Generator Status

Step 7Step 7 Taking On Communication Labeling Taking On Communication Labeling ChallengeChallenge

• Automating the Labeling ProcessAutomating the Labeling Process

• Manually Labeling in the PharmacyManually Labeling in the Pharmacy

• Providing Guidance on the FloorProviding Guidance on the Floor

• Selecting a Message for the LabelSelecting a Message for the Label

• Advocate that distributors or Advocate that distributors or manufactures label drugs further manufactures label drugs further up the food chainup the food chain

Step 8Step 8 Consider Management Options Consider Management Options

• Segregation at the Point of GenerationSegregation at the Point of Generation

• Centralizing SegregationCentralizing Segregation

• Managing all drug waste as hazardousManaging all drug waste as hazardous– May be simplest and most economical May be simplest and most economical

approach for small facilities with < 50 bedsapproach for small facilities with < 50 beds– May cost large metropolitan facilities in May cost large metropolitan facilities in

excess of $1Mexcess of $1M

Sample Guidance PosterSample Guidance Poster

Step 9Step 9 Getting Ready for Implementation Getting Ready for Implementation

• Locating Your Satellite Accumulation Locating Your Satellite Accumulation AreasAreas

• Evaluating Your Storage Accumulation Evaluating Your Storage Accumulation AreaArea

• Selecting the Right VendorsSelecting the Right Vendors

• Conducting PilotsConducting Pilots

• Putting it all together: Policies and Putting it all together: Policies and ProceduresProcedures

• Preparing for SpillsPreparing for Spills

Locating Satellite Accumulation Locating Satellite Accumulation AreasAreas

• Located at the point of generation and under control of Located at the point of generation and under control of operator operator (check with state)(check with state)

– Soiled utility room in nursing unitSoiled utility room in nursing unit– Sterile processing clean room and other areas of Sterile processing clean room and other areas of

pharmacypharmacy• Hazardous waste labelHazardous waste label• Signage indicating Satellite AccumulationSignage indicating Satellite Accumulation• Keep container covered when not in active useKeep container covered when not in active use• Quantity LimitQuantity Limit

– Up to 1 quart of P listed waste and 55 gallons of combined U Up to 1 quart of P listed waste and 55 gallons of combined U and characteristic wasteand characteristic waste

• Have 3 days to move when limit is reachedHave 3 days to move when limit is reached

Step 10 Launch the ProgramStep 10 Launch the Program

• Educate & Train StaffEducate & Train Staff

• Staging the Roll-outStaging the Roll-out

• Paperwork Requirements: Filling Paperwork Requirements: Filling Out Required FormsOut Required Forms– Hazardous Waste ManifestsHazardous Waste Manifests– Land Disposal RestrictionsLand Disposal Restrictions

• Tracking, Measuring & Tracking, Measuring & Recording ProgressRecording Progress

Federal Role:Federal Role:

Agency InterestsAgency Interests

ResearchResearch

Policy ImplicationsPolicy Implications

Disposal GuidelinesDisposal Guidelines

EPA Regulatory AgendaEPA Regulatory Agenda

• Considering revising Universal Waste Rule Considering revising Universal Waste Rule for inclusion of some waste for inclusion of some waste pharmaceuticalspharmaceuticals

• Office of Water evaluating the healthcare Office of Water evaluating the healthcare sector, including disposal of pharm waste sector, including disposal of pharm waste from institutions, to determine need for from institutions, to determine need for development of WQ criteriadevelopment of WQ criteria

Health Services Industry Study Outreach Health Services Industry Study Outreach January 2008January 2008

What is the Scope of the Study?What is the Scope of the Study?• We are studying the disposal of unused pharmaceutical from the We are studying the disposal of unused pharmaceutical from the

Health Services Industry (hospitals and long-term care facilities) as Health Services Industry (hospitals and long-term care facilities) as part of the EPA’s CWA Effluent Guidelines Programpart of the EPA’s CWA Effluent Guidelines Program

• We are looking to highlight good voluntary best management We are looking to highlight good voluntary best management practices practices

What are We Studying?What are We Studying?• Identifying current management of unused pharmaceuticals at long-Identifying current management of unused pharmaceuticals at long-

term care facilities and hospitalsterm care facilities and hospitals• Summarizing federal, local, and regional requirements, guidance, Summarizing federal, local, and regional requirements, guidance,

and voluntary initiativesand voluntary initiatives• We are soliciting volunteers to fill out a data requestWe are soliciting volunteers to fill out a data requestWhat is our Schedule?What is our Schedule?• August 2008 Preliminary Report of Health ServicesAugust 2008 Preliminary Report of Health Services

EPA’s Health Services Industry Detailed Study

Federal Disposal GuidelinesFederal Disposal GuidelinesFeb. 20, 2007 Feb. 20, 2007

• Federal govt. guidelines for proper disposal of unwanted Federal govt. guidelines for proper disposal of unwanted medicationsmedications– ONDCP issued February 2007ONDCP issued February 2007– Reaches across several Federal agenciesReaches across several Federal agencies– Encourages trash disposal—after drugs made Encourages trash disposal—after drugs made

unusableunusable– Discourages flushingDiscourages flushing

Federal Disposal GuidelinesFederal Disposal Guidelines• Take unwanted meds out of original containers & put Take unwanted meds out of original containers & put

in trashin trash• Mix prescription drugs with undesirable substance, Mix prescription drugs with undesirable substance,

(e.g., used coffee grounds or kitty litter) & put in (e.g., used coffee grounds or kitty litter) & put in impermeable, non-descript containersimpermeable, non-descript containers

• Flush only if label says to do soFlush only if label says to do so– FDA lists 13 pharms that should be flushedFDA lists 13 pharms that should be flushed

• Use community return programs where availableUse community return programs where available

http://www.whitehousedrugpolicy.gov/drugfact/factsht/http://www.whitehousedrugpolicy.gov/drugfact/factsht/proper_disposal.htmlproper_disposal.html

SMARxT DisposalSMARxT DisposalThe SMARXT DISPOSAL campaign is designed to raise awareness about the potential environmental impact from improperly disposed of medications and to provide proactive guidance through proper disposal alternatives.

SMARXT DISPOSAL is a unique public-private partnership between the U.S. Fish and Wildlife Service, the American Pharmacists Association, and the Pharmaceutical Research and Manufacturers of America. This support and involvement is what separates SMARXT DISPOSAL from other initiatives and it will ultimately make this campaign successful.

Website just released! SMARxTDisposal.net

Stewardship ActivitiesStewardship Activities

Types of Stewardship ActivitiesTypes of Stewardship Activities

• 1-time consumer return collections1-time consumer return collections• Household haz waste collectionsHousehold haz waste collections• Permanent collection boxesPermanent collection boxes• Use of police stationsUse of police stations• Pilot use of reverse distributorsPilot use of reverse distributors• Pilot mail-back programsPilot mail-back programs• Many of these programs require Many of these programs require

involvement of a pharmacist (DEA)involvement of a pharmacist (DEA)

EPA Stewardship ActivitiesEPA Stewardship Activities

• EPA’s new PPCP web siteEPA’s new PPCP web site http://www.epa.gov/ppcp/

• 2 recently funded programs in Maine & 2 recently funded programs in Maine & Missouri thru Aging InitiativeMissouri thru Aging Initiative– Mail-back & take-back return programsMail-back & take-back return programs– Inventories of types & quantities of drugs Inventories of types & quantities of drugs

returnedreturned

Northeast Recycling Council grantManagement of Unwanted Pharmaceuticals

• Researching and addressing legal issues with take-back programs,

• Developing drug collection pilots, including one nearby in South Portland, Maine,

• Developing a “Guidebook for Holding Unwanted Medication Collections,”

• Developing Best Management Practices for the end-of-life management of plastic medication containers.

Website – where you can download all materials http://www.nerc.org/projects/completed_projects.html#2006-a

Adapted from Region 2 August 2006Adapted from Region 2 August 2006 4747

Results EPA Region II:Results EPA Region II:Compliance Monitoring & Incentives ProgramsCompliance Monitoring & Incentives Programs

HospitalsHospitals

UniverseUniverse480480

InspectionsInspections4949

Enforcement ActionsEnforcement Actions 3636

Formal Enforcement ActionsFormal Enforcement Actions 11 ($1,523,613)11 ($1,523,613)

SettlementsSettlements 9 ($642,612)9 ($642,612)

Audit AgreementsAudit Agreements 4141

Voluntary DisclosuresVoluntary Disclosures 156 covering 581 facilities ($29,947,688 156 covering 581 facilities ($29,947,688 for 143 resolved)for 143 resolved)

Violations CorrectedViolations Corrected 32233223

Adapted from Region 2 August 2006 Adapted from Region 2 August 2006 presentationpresentation

4848

Healthcare Violations – All R2Healthcare Violations – All R2

Breakout of Violations from Hospital Disclosures

Safe Drinking Water Act -SDWA

Violations0%

Emergency & Planning

Community Right to Know -EPCRA

Violations7%

-Clean Air Act CAA Violations

18%

- Clean Water Act CWA Violations

4%

Toxic Substance Control Act-TSCA

Violations1%

-Hazardous Waste RCRA Violations

70%

Adapted from Region 2 August 2006 Adapted from Region 2 August 2006 presentationpresentation

4949

Top 5 ViolationsTop 5 Violations ( (From 146 Voluntary Disclosures)From 146 Voluntary Disclosures)

RankRank ViolationViolation StatuteStatute FrequencyFrequency

11 ID of Hazardous ID of Hazardous Waste Waste

RCRA – RCRA – Hazardous Hazardous wastewaste

592592

22 Universal WasteUniversal Waste RCRA– RCRA– Hazardous Hazardous wastewaste

446446

33 Container Container ManagementManagement

RCRA– RCRA– Hazardous Hazardous wastewaste

331331

44 LabelingLabeling RCRA– RCRA– Hazardous Hazardous wastewaste

304304

55 CFC Leak Detection CFC Leak Detection Records Records

CAA – CAA – Clean Air ActClean Air Act 264264

Adapted from Region 2 August 2006 Adapted from Region 2 August 2006 presentationpresentation

5050

Healthcare RCRA ViolationsHealthcare RCRA Violations

Breakout of RCRA Violations from Hospital Disclosures

Accumulation Time1%

Manifest 5%

ID of HW 26%

Universal Waste20%

General Facility Standards10%

Container Management30%

UST 3% Generator

Requirements5%

Region II Data – New DataRegion II Data – New Data

• Region II summer intern recently reviewed Region II summer intern recently reviewed disclosures for "failure to identify" and disclosures for "failure to identify" and "mischaracterization of HW" related "mischaracterization of HW" related violations. violations.

• Data based on 100 hospitalsData based on 100 hospitals

ViolationViolation TypeTypeViolation Type

0

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120

140

160

180

200

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Hazardous Waste Hazardous Waste CharacterizationCharacterization

Hazardous Waste Characterization

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40

60

80

100

120

140

160

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54

A voluntary partnership with EPA

ENERGY STAR is…

A strategic approach to energy management

Energy StarPurchasing and Procurement

• Buy Energy Star Products

Product information

Cost saving information, saving calculators

Procurement information, sample language

http://www.energystar.gov/index.cfm?c=bulk_purchasing.bus_purchasing

• Take free on-line procurement training, http://energystar.premiereglobal.com/attendee/ConferenceList.aspx

56

General Resources

Healthcare Environment Resource Centerwww.hercenter.org

Healthcare Without Harmhttp://www.noharm.org/

Sustainable Hospital Projecthttp://www.sustainablehospitals.org/cgi-bin/DB_Index.cgi

Practice Green Health (includes former H2E)http://www.h2e-online.org

General Resources (Cont.)

• Building Healthy Hospitals: Top 5 Green Building Strategies for Healthcare (2007)

• #1 Energy Efficiency • #2 Process Water Efficiency• #3 Sustainable Flooring Material Selection• #4 Indoor Air Quality: Material Selection• #5 Lighting Efficiency

http://www.epa.gov/region09/waste/p2/greenbldg.html

Questions ?

Want to join EPA Region 1’s hospital email group for regular updates on environmental issues?

Janet Bowen, EPA Region 1

617-918-1795

Bowen.Janet@epa.gov