Pharmaceuticals

Michigan DEQ Launches New Drug Disposal Web Page

Training: 49 CFR 172, Subpart H and 40 CFR 265.16

Training for RCRA Personnel and HazMat Employees in Michigan

On April 29th, 2016 the Michigan Department of Environmental Quality (MDEQ) launched its new Drug Disposal Web Page for businesses and citizens of Michigan.  It includes:

  • Locations and information on drug “takeback” activities throughout the state.
  • Provides information for the healthcare industry on proper drug disposal.
  •  Drug disposal options for both households and non-households, i.e. commercial or industry.
  • Universal Waste Guidance in Michigan.  Why?  Because Michigan is one of only two states – what up Florida? – that allows disposal of pharmaceuticals as a universal waste.  View my presentation on this topic:  The Identification and Management of Universal Waste in Michigan.
Unwanted drugs should not be flushed down the drain!

More on Michigan:

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

The USEPA Hazardous Waste Pharmaceuticals Wiki

From the USEPA website:  Hazardous Waste Pharmaceuticals Wiki

EPA launched the Hazardous Waste Pharmaceuticals Wiki  as a public platform for healthcare professionals to share their expertise regarding whether pharmaceuticals are hazardous waste when discarded. Professionals in the healthcare industry must register to edit and contribute new information to the wiki, pending EPA’s approval. Anyone may view the Wiki without registering. This project will foster compliance with the Resource Conservation and Recovery Act in the healthcare industry by aiding that first crucial step in managing hazardous waste: determining that the waste is indeed a hazardous waste.

Who can Participate?

Members of the healthcare community are invited to participate. This includes healthcare professionals, state and local agencies, tribes, federal agencies, consultants, nonprofit organizations, and members of industry and professional organizations, among others. Anyone can view the Hazardous Waste Pharmaceuticals Wiki, but only those in the healthcare community may contribute to or edit the Wiki.

How can I Participate?

  • Share your expertise in waste determinations to aid in the proper disposal of hazardous waste pharmaceuticals to protect human health and the environment.
  • Add information specific to your State’s hazardous waste programs to aid others located in that State.
  • Share helpful links to assist others in the healthcare community.

Visit the Hazardous Waste Pharmaceuticals Wiki  for more information, including instructions on how to register.

What if I’m not a Healthcare Professional?

This Wiki is intended to help healthcare professionals that discard pharmaceuticals; it is not intended for household consumers of pharmaceuticals. The status of pharmaceuticals as hazardous waste should not imply that they are unsafe for use when they are taken as directed. For recommended disposal practices of pharmaceuticals by household consumers, see Pharmaceuticals and Personal Care Products (PDF).

It is important to note that an improper hazardous waste determination for pharmaceutical waste is a frequent cause of RCRA violations at hospitals and medical facilities.  I recommend you take advantage of this wiki to improve your knowledge of pharmaceutical disposal and perhaps provide information that may help others.

Please don’t hesitate to contact me with any questions you may have about the management of hazardous waste at a hospital or pharmaceutical manufacturer.

HOUSEHOLD MEDICATION DISPOSAL EVENT AT THE STATE CAPITOL – TUESDAY, SEPTEMBER 10, 2013

Summer is moving fast and the Michigan Pharmacists Association (MPA) annual medication collection at the Capitol is upon us again. Clean out your medicine cabinet and bring your unused,
unwanted, or expired household medications to the south Capitol lawn for safe disposal on Tuesday, September 10th from 10 a.m. to 1 p.m. If you are short of time, utilize the drop off tent on the east Capitol lawn at the intersection of Capitol Avenue and Michigan Avenue.

Items accepted include: controlled substances, narcotics, over-the counter medications, prescription medications, eye drops, inhalers, insulin, medicated ointments/lotions, medication samples, including pet medications, and vitamins/supplements from your home.

Items not accepted include: waste medications from businesses, medical waste (infectious sharps, needles, and syringes), or medications that are a hazardous waste or a hazardous drug (chemotherapy medications).

To hear more about the joint efforts to ensure safe drug disposal, preserve our drinking water, and prevent drug abuse, join us for the press conference at 11 a.m. on September 10th. To locate other medication collection locations, please see the Remedy for Residential Drug Disposal Brochure. For more information on this event, please contact the DEQ’s Environmental Assistance Center at 800-662-9278 or deq-assist@michigan.gov.

Fortunately for businesses that are not able to take advantage of this program, pharmaceuticals are a Universal Waste in Michigan.  Under the regulations of the Resource Conservation and Recovery Act (RCRA), Universal Wastes may be managed at a lower level of regulatory responsibility.  View this short presentation in order to learn more about the management of Universal Waste in Michigan.

Pharmaceuticals as Hazardous Waste

(Kansas City, Kan., Nov. 23, 2011) – Eldo W.R.M.S., Inc., a commercial goods salvage wholesale and retail business, has agreed to pay a $23,900 civil penalty to the United States to settle a series of hazardous waste violations at its facility in Grandview, MO (more).  Read the whole news release and you’ll learn that the most significant violation had to do with the incorrect on-site management and off-site disposal of pharmaceuticals.  You may be surprised to learn that pharmaceuticals are not identified specifically in the RCRA regulations (40 CFR 239 to 299), nor is there any exclusion from the regulations allowed.  Rather, they are subject to the hazardous waste determination requirements of 40 CFR 262.11 the same as any other discarded material and may have to be managed as a hazardous waste.  It may also surprise you to learn that there are no US EPA regulations specifically regarding the management or off-site shipment of medical waste.  In the absence of Federal regulation of medical waste, many states have created their own, but they don’t include pharmaceuticals (see here for more information).  If you generate pharmaceuticals as a waste, you should be aware of the applicable regulations, your disposal options, and some potential regulatory relief coming down the pike.

This US EPA website has a lot of helpful information about pharmaceuticals:  what they are, their dangers, and proper disposal methods; as part of a larger group of potential pollutants known as Pharmaceuticals and Personal Care Products (PPCP’s).  PPCP’s include:

  • Prescription and over-the counter therapeutic drugs
  • Veterinary drugs
  • Fragrances
  • Cosmetics
  • Sun-screen products
  • Diagnostic agents
  • Nutraceuticals (e.g., vitamins)

Sources of PPCP’s include:

  • Human activity
  • Residues from pharmaceutical manufacturing (well defined and controlled)
  • Residues from hospitals
  • Illicit drugs
  • Veterinary drug use, especially antibiotics and steroids
  • Agribusiness

The dangers to the environment from PPCP’s lies in their ability to infiltrate water systems relied upon for drinking water or wildlife, thus the importance of compliance with the regulations.  Without any current regulations addressing PPCP’s specifically, you must manage it as any other discarded material:

  • Determine if it is subject to any of the regulatory exemptions for solid waste or hazardous waste.
  • Determine if it is subject to the recycling exemption.
  • Determine if it is either a listed or characteristic hazardous waste.
  • If it is a hazardous waste, count it towards your generator status threshold.
  • Comply with the applicable regulatory requirements of your generator status.
  • Ensure your off-site transportation and disposal is with a licensed hazardous waste hauler and medical waste disposal facility.

I mentioned the possibility of regulatory relief, didn’t I?  There is a proposal to include pharmaceuticals with the current universal wastes.  This could be a great relief to generators of this waste as the universal waste regulations allow for longer on-site accumulation, less stringent container requirements, and little to no inspection and training; learn more about universal waste here.

Pharmaceuticals and PPCP’s are just one of many types of waste that require your attention.  If you generate any hazardous waste or ship or receive any hazardous material, you will benefit from my training events where I meet and exceed both the US EPA hazardous waste and the US DOT HazMat Employee training requirements in one day.  Review my schedule to find a date and location convenient to you or contact me to schedule on-site training.