It’s time to clean out those cabinets full of pharmaceutical samples and expired drugs.
Have you been tossing your unwanted pharmaceuticals or expired pharmaceuticals in the trash or down the drain? Of course not, we know you’re better than that! There are some very important best practices for pharmaceutical waste disposal and it is vital that you know them to keep you, your practice, and the environment safe.
You must understand the EPA’s pharmaceutical waste requirements, properly segregate your waste, and educate your staff on the procedure in place for managing pharmaceutical waste.
Below you’ll find two truths and one very common lie about managing unwanted or expired pharmaceuticals.
Truth: Not All Pharmaceutical Waste is Created Equal
You must segregate your pharmaceutical waste prior to disposal and destruction. The first step in this process is to perform a comprehensive analysis of every pharmaceutical substance at your practice. Clean out those shelves and cabinets! Then, you need to segregate the unwanted pharmaceuticals based on type. The substance could be over the counter pharmaceuticals (OTC) or prescription pharmaceuticals (Rx). It could also be schedules I-V in which case there will be a few more steps involved in disposing of the substance.
In addition, segregation of schedules I-V substances is crucial. This is where the regulations come into play.
Truth: There ARE Regulations for Disposal of Pharmaceuticals
Schedules I-V pharmaceuticals, also known as controlled substances, must be treated differently than OTC and Rx. In addition, there is an extra step involved in disposing of schedules I-II pharmaceuticals. For schedules I-V substances you will need to inventory all products being sent for destruction. The Controlled Substances Act (CSA) administered by the DEA provides a closed system for distributing controlled substances. As part of this, you will need to fill out a Controlled Inventory Transfer Form to start the transfer of controlled substances. All controlled substances must be accurately and officially documented.
Healthcare facilities can always contact their state environmental regulatory agency to ensure full compliance.
Lie: It is Safe to Dump Unwanted Medication Down a Drain
According to new research, small amounts of pharmaceuticals entering the environment through wastewater have made their way into aquatic environments through improper disposal of medications. While the main way drug residues enter the water system is as a result of people taking medication and passing it through their bodies naturally, this is still an issue. Raanan Bloom, Ph.D., an environmental assessment expert in FDA’s Center for Drug Evaluation and Research says that “while FDA and the Environmental Protection Agency take the concerns of flushing certain medicines in the environment seriously, there has been no indication of environmental effects due to flushing,” says Bloom. “Nonetheless, FDA does not want to add drug residues into water systems unnecessarily.”
DEA regulations say that controlled substances need to be destroyed in a manner “beyond reclamation” (DEA, 2012). We must eliminate the common practice of disposing of unwanted pharmaceuticals down toilet or sink drains. The proper management of all drugs, especially controlled substances, needs to be thought of with the waste management process in mind.