Pharmaceutical Waste Identification Checklist

Hazardous Drug Disposal Service

Pharmaceutical Waste Identification Checklist – Surgical Center

The U.S. Environmental Protection Agency (EPA) requires all businesses to evaluate waste materials, make a waste determination through “waste characterization”, and determine the amount of hazardous waste (per the Resource Conservation and Recovery Act – RCRA)they generate in a month prior to disposal. This is required to properly identify generator status of either Conditionally Exempt Small Quantity Generator (CESQG), Small Quantity Generator (SQG) or Large Quantity Generator (LQG) which will have varying requirements.1 This requirement extends to waste pharmaceuticals being disposed of by healthcare facilities. Stericycle has developed this checklist as an assessment tool to help healthcare facilities identify their pharmaceutical wastes (unused portions of left over, outdated, or sample drugs) and dispose of them appropriately.

As always, you should refer to your state or local regulatory agency’s requirements to determine the best solution for your unique needs. State or local regulations may be more stringent or different than the EPA requirements. 1Source: http://www.epa.gov/rcra/resource-conservation-and-recovery-act-rcra-overview SECTION 1: Identifying Compatible Pharmaceutical Waste This partial list of compatible pharmaceutical waste denotes pharmaceutical items that can be placed together in the same container for disposal without risk of a chemical reaction. CHECK ANY OF THE FOLLOWING THAT YOU CARRY: 1. Anesthesia/Topical: 4. Dermatology: 7. Ophthalmology:  Chloroform  Fluocinonide Topical, Lidex  Blephamide  Isoflurane/Desflurane  Fluorescein Sodium  Fml S.o.p, Fluoromethalone  Glycopyrrolate Bromide  Lice Treatment Shampoos, Nix  Neomycin/Polymyxin/  Phisohex  Lindane Shampoo Or Lotion Dexamethasone  Sevoflurane  Resorcinol  Neo-Synephrine  Silvadene, Silver Sulfadiazine  Selenium Sulfide, Dandrex,  Viroptic, Trifluridine 2. Cardiology: Exsel, Selsun Blue, Selseb, Selenos,  Vision Blue, Trypan Blue  Argatroban Tersi Foam 8. Vaccines:  Digoxin  T-Gel, Iniol-T, Polytar, Zetar, Do you vaccinate your patients?  Epinephrine*, Epipen, Coal Tar  Yes  No Epi-Foam, Twinject, Primatene, 5. Diabetes Treatment: 9. Vitamins/Nasal/Oral: S2, Adrenaline  Byetta  Afrin  Nitroglycerine*, Nitrostat,  Humalog, Humulin  Chromium Nitroquick, Nitro-Dur,  Iletin  Cough Syrup Nitro-Bid  Insulin  Glucerna, Boost, Jevity,  Reserpine  Novolog, Novolin Nepro, Osmolite, Multigen, 3. Chemotherapy:  Lantus Poly-Vi-Sol  Azaserine  Levemir  Multivitamins  Chlorambucil, Leukeran  Symlin  Multigen  Cyclophosphamide, Cytoxan, Neosar 6. Flammables:  Paricalcitol  Daunomycin, Daunorubicin,  Formo Cresol, Cresol Solution  Phenol Cerubidin, Daunxome, Rubidomycin  Mouthwashes  Protegra  Diethystilbestrol, Des, Stilphostrol  Phosphate Binders  Selenium  Melphalan, Alkeran, L-Pam  Unused/Expired Alcohol Pads,  Mitomycin, Mitomycin C, Alcohol Swabs Mutamycin  Streptozotocin, Zanosar *In the vast majority of states, medical-grade Nitroglycerine  Uramustine, Uracil Mustard, Mustargen and Epinephrine are exempted from P-listed status. SECTION 2: Identifying P-Listed Hazardous Pharmaceutical Waste P-listed hazardous waste, also known as “acutely hazardous waste,” is subject to a special set of EPA regulatory requirements due to its high toxicity to human health and the environment. To avoid being considered an Large-Quantity Generator (LQG), P-listed pharmaceutical waste and its immediate packaging (blister packs, vials, wrappers, bottles, etc.) should be collected separately from other pharmaceutical waste and monitored so that the total amount on-site does not exceed 2.2 pounds. CHECK ANY OF THE FOLLOWING THAT YOU CARRY:  Arsenic Trioxide/Trisenox  Nicotine Patches, Lozenges & Gums  Coumadin/Jantoven/Warfarin  Physostigmine, Physostigmine Salicylate

SECTION 3: Identifying Incompatible Pharmaceutical Waste A small number of medications, known as “incompatible” pharmaceutical waste, must be collected and transported in their own containers, per current DOT requirements, separate from compatible waste and from one another, to prevent a chemical reaction from occurring. Following is a list of incompatible pharmaceuticals. Additionally, some items such as Botox/Myobloc, while not regulated under RCRA, it still must be collected and transported in its own container, separate from all other pharmaceutical separate from all other pharmaceutical waste, for proper final destruc- tion. Please note that each underlined category listed below requires its own container, separate from all other pharmaceutical waste. CHECK ANY OF THE FOLLOWING THAT YOU CARRY:  Aerosols (includes asthma inhalers, Hurricane)  Corrosive Acids (includes aluminum  Ignitable (includes Velphoro and  Botox/Myobloc chloride injections, Tri-Chlor, ammonia Zemplar) inhalants, cupric/copper/chromium  Oxidizers (includes unused Silver Nitrate  Collodion/Nitrocellulose chloride, hydroxyzine hydrochloride, (includes New Skin, wart removers) sticks/applicators, Arxol Silver, Amyl L-Cysteine, lactic acid, Pyridoxine HCL Nitrate, Cyanide Antidote kits) injection, Sporanox)

SECTION 4: Estimating Pharmaceutical Waste Volume Thinking of a typical office/desk-side trash can (approximately 8 gallons and roughly 12” diameter x 18” high), how often would it take you to fill with pharmaceutical waste (excluding controlled substances)? CESQG may be subject to lesser restrictions, however state specific regulations may apply. To check your generator status and learn more about EPA’s Federal Requirements please visit: http://www2.epa.gov/hwgenerators/hazardous- waste-generator-regulatory-summary.  One Week or less  Three Months  Twelve Months  One Month  Six Months

SECTION 5: Definition of Acceptable Pharmaceutical Waste Thank you for doing your part to stay compliant. This the first step toward building a pharmaceutical waste profile for your organization. Please review and complete the following information in order to allow us to initiate services.

YES, I certify that these containers will be used only for collection of RCRA hazardous and non-hazardous pharmaceutical waste. I certify that no DEA controlled substances, infectious or regulated medical wastes (RMW) or non-pharmaceutical wastes of any kind will be included in these containers. I certify that I will collect my incompatible pharmaceutical waste separately from my compatible pharmaceutical waste. I agree to place only wastes conforming to these descriptions into these containers.

Name: ______Signature: ______Position/Title: ______Date: ______Phone: ______Fax: ______Email: ______System Name/Affiliation: ______Facility Name: ______Facility Address: ______Facility City/State/Zip: ______Customer Number: ______Site ID: ______Please return to: ______Fax / Email: ______Disclaimer: Stericycle’s Hazardous Drug Disposal Service, an offering among its Healthcare Compliance Solutions, is not intended to serve as and does not constitute legal or regulatory advice. No information provided should be relied upon and used as a substitute for consultation with qualified legal, regulatory or other professional advisors. Information provided by Stericycle is intended to serve as general guidance, for informational purposes only. The use of any of Stericycle’s Healthcare Compliance Solutions is neither required by nor guarantees compliance with federal, state or local laws.