Pharmaceutical Waste
Management Program
University of Chicago Medical Center
Introduction
• University of Chicago Medical Center (UCMC) will be
implementing a program to collect Pharmaceutical (Rx)
waste throughout the hospital.
– The program has been designed to collect and manage this
waste using Best Management Procedures.
• Training Module:
– This training module is designed to explain the requirements,
describe the identification process, and show how
pharmaceuticals will be identified by the Pharmacy and
collected in various containers in all departments of the
hospital.
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Introduction
• Program Overview
– Pharmacy evaluates the hospital formulary and develops a quick and
easy way (through identifiers) to indicate where to place the waste.
– Staff administers the Pharmaceutical and looks for the identifier(s) to
determine where to dispose of waste.
– Staff disposes of the Pharmaceutical waste in containers placed
strategically in their Unit.
– Staff will be required to know where to dispose of each type of
Pharmaceutical waste.
– Staff will not be required to memorize what to do with each
Pharmaceutical waste.
– Stericycle (third party) staff will be responsible for Pharmaceutical
waste container service and transport.
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Who to Contact With Questions
• If there are any questions regarding this new
program, please see the educational postings
in each unit or contact the following individuals:
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– Jennifer Palombizio, Manager of Safety Office and
Environmental Compliance, 2-3363, 5-SAFE or
jennifer.palombizio@uchospitals.edu
– Judd Johnson, Assoc. Dir – FD&C, 2-8259 or
jjohnson@bsd.uchicago.edu
– If the above individuals are not available, the
Pharmacy Director can be contacted
Regulatory Environment
• In addition to promoting Environmental Stewardship, there are regulations
that apply to the management and disposal of pharmaceutical wastes
• What are healthcare facilities required to do?
– Manage all identified Hazardous Waste generated within the facility
(Pharmaceuticals, Lab Wastes, Engineering, Solvents, etc.). This program
concentrates on the Pharmaceutical Wastes
– Some Pharmaceuticals are considered hazardous to the Environment and
therefore UCMC will manage accordingly
– Rules and Regulations (EPA, IL EPA, DOT, The Joint Commission)
• Federal: US Environmental Protection Agency
– Rules developed in 1976, recently began looking at Healthcare
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• State: Illinois Environmental Protection Agency
• Additional Regulations – Department of Transportation (when shipping),
Sewered Waste (drain disposal), The Joint Commission – Environment of
Care
Current Rx Waste Practices
Rx waste is currently being disposed of in a variety of non-compliant ways. The
table below shows some common locations where Rx waste is being disposed,
what can continue to go into those containers, and what cannot.
Rx Waste Currently Disposed of In:
What Will Continue to be Disposed
into Existing Container
What Will no Longer be Disposed
of into Existing Container
Bio-Hazardous/Red Bag
Infectious waste, gauze w/
infectious material (may contain
some Rx)
IVs, vials, oral meds, wrappers,
inhalers that are NOT infectious
Sharps Container
Syringes and sharps
Full, partial and empty Rx vials , oral
meds, wrappers, inhalers
Regular Trash
Garbage, outside packaging,
package inserts, over wrap
Full, partial and empty Rx vials and
IVs, oral meds, wrappers, inhalers,
creams
Drain/Sewer
Controlled substances, maintenance
IV solutions, basins of irrigation
solutions from ORs
Full, partial and empty Rx IVs, oral
meds (except controlled
substances), antibiotics
Yellow Chemo Container
Empty Chemo vials and IVs, empty
syringes, non-contaminated gloves
& gowns
Full or partial Chemo containers
(vials and IVs), Chemo spills,
contaminated gloves & gowns
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Processes Not Changing
• Controlled Substances Handling
– Still must witness and waste to drain per DEA guidance and written
procedures
• Radioactive Rx and Nuclear Medicine Procedures
– Follow existing procedures with half life decay, etc.
• Regulated Medical Waste
– Sharps (needles, etc.) = Sharps Container
– Red bag wastes = Red Bag/Infectious Waste Container
• IV Draining
– Can still cut and drain non-pharmaceuticals to the drain and bags to the
garbage
• Maintenance IVs and Fluids (saline, potassium, sodium chloride, D5W, etc.)
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– If Pharmaceutical is added, then manage as it is identified
Examples of Rx Waste To Collect
The rules apply not only to the Rx in various forms and doses, but
also applies to some containers that held the Rx. Examples of
items to collect:
• Vials
• IVs and tubing
– Doesn’t Include Maintenance IVs (Saline,
LRs, Dextrose, KCl, Na Bicarb)
• Oral Medications
• Partial syringes
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• Unit dose packaging
– Specifically - Coumadin unit dose
packaging, nicotine patch and
backing
• Patient prescriptions
– Left from patients and families
Categories of Rx Waste
• Rx can be either Hazardous or Non-hazardous to the
Environment (different from OSHA Hazardous or Bio-Hazardous
definitions)
• Hazardous Rx Waste – About 6% of formulary
– Rx might be identified as hazardous to the environment because it is
specifically listed (Warfarin, Nicotine)
– Some Rx is hazardous because the Rx has something in it
• Rx with Alcohol is Ignitable; Some Rx are Corrosive
• Some Rx contain preservatives (Thimerisol) that make them hazardous
• Non-Hazardous Rx Waste – About 93% of the formulary
– Most Rx are not hazardous according to EPA definitions but many of these
Rx may still adversely affect the environment
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• As a best management practice, UCMC will also collect all non-hazardous Rx
and dispose through incineration
Identifying Rx Waste Streams
• How to Identify Pharmaceuticals:
– A Formulary Analysis has been completed by the Pharmacy to
identify what Rx need to be managed in which container
– Pharmacy will Identify the Hazardous Rx for disposal in Black
containers
• AcuDose or EPIC MAR notification for those that are distributed
through the AcuDose System
– “Dispose in Black Container”
– “For Disposal Return to Pharmacy”
• Rx that has no AcuDose or MAR message or label, is NonHazardous and is disposed of in the BLUE Container
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WHAT ARE THE DIFFERENT TYPES
OF RX WASTE?
Sewerable Wastes
Compatible Hazardous Waste
Incompatible Hazardous Waste (Separate)
Chemotherapy Wastes
Non-Hazardous Waste
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Pharmaceutical Waste Stream Management
Labeled or Identified as Hazardous / Incompatible Rx by Pharmacy
Sewer System
Items that can be
cut and poured
down the drain
•Plain IV Solutions
•Solutions
containing
additives, such as:
Hazardous Rx
Waste
“Place in BLACK
Container”
Incompatible Rx
Waste
“Return to
Pharmacy”
Items identified
with a message or
black dot
Incompatible Rx
Wastes Require
Segregation to Meet
DOT, Safety &
Disposal
Requirements
Examples
 Insulin
 Some Vaccines
Trace elements
 Coumadin
 Potassium
chloride
 Potassium
phosphate
 Sodium
phosphate
 Calcium
 Sodium
bicarbonate
 Nicotine
 Unused Silver
Nitrate
 Rx in Syringe –
Discharge into
gauze, gauze in
container, syringe
to SHARPS
Corrosives
(Examples)
Cut and
Discharge to
Drain
No Messaging
Chemotherapy Rx
and containers that
ARE empty
Not Labeled or
Identified as
Non-Hazardous Rx
by Pharmacy
Examples
Chemo Agents
Empty Syringes
Examples
IVs with Residual
Chemo Agents
Gowns with chemo
small amount of
contamination
•Antibiotics
 Inhalers with
canister
 Rx Spill Cleanup
Debris
Non-Hazardous
Rx Waste
Chemotherapy Rx
and containers that
are NOT empty
Aerosols
Oxidizers (Examples)
Bulk & Trace Chemotherapy Rx
Waste
A Combination of
Infectious Waste &
Hazardous Rx
Waste
Place in zip lock bag
Miscellaneous
•Controlled
Substances
Potentially Infectious
& Hazardous Rx Waste
“Return to
Pharmacy”
L-cysteine (in
pediatric TPN)
Corrosives
(Examples)
Must
meet by
the
Hazardou
s and
Infectiou
s Waste
Definitio
ns
Chemo Spill
Cleanup Debris
Gloves
Vials with Residual
Chemo Agents
Goggles
Tablets, caps etc.
Empty IVs / Tubing
Wipes
Vials
Manage
d like a
spill
response
•Lidocaine
•Marcaine
•Heparin
Miscellaneous
• Full/partially filled
syringe – expel
into gauze, gauze
in container,
empty syringe in
SHARPS
 Botox
Place into
BLACK
CONTAINER
Place into a
BAGGIE and
RETURN TO
PHARMACY
SHARPS
 Needles
Empty syringes (See Above)
Empty controlled substance containers
Call EVS for
PURPLE
CONTAINER
Place into
BLACK
CONTAINER
Place into
YELLOW
CONTAINER
REGULAR TRASH
Place into BLUE
CONTAINER
Outside packaging and overwrap that did not contact Rx
Regular Trash
Shipping packaging
Sewer System
Items that can be
cut and poured
down the drain
SEWERABLE WASTES
Plain IV Solutions
Controlled Substances
•Plain IV Solutions
•Solutions
containing
additives, such as:
Potassium
chloride
Potassium
phosphate
Sodium
phosphate
Calcium
Sodium
bicarbonate
•Controlled
Substances
Cut and
Discharge to
Drain
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Plain IV Solutions
• Plain IV Solutions are those prepackaged items that did not
have Rx added to it
• Continue to drain Plain IV Solutions to the drain and the bags
then go to the Garbage
• These Plain IV Solutions Include:
 Saline
 Lactated Ringers
 Potassium chloride
 Potassium phosphate
 Sodium phosphate
 Calcium
 Sodium bicarbonate
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Controlled Substances
• Continue to follow DEA witness/waste requirements per your
Hospital’s Policy
• Witness and waste to the drain, sink, toilet
• Do NOT dispose controlled substances:
–
–
–
–
In RMW containers
In Hazardous Rx waste containers
In Non-hazardous Rx waste containers, or
In Trash
• Once empty, the containers can be placed into the Sharps
container or Blue Non-hazardous Rx waste container
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Hazardous Rx
Waste
“Place in BLACK
Container”
COMPATIBLE HAZARDOUS
RX WASTES
Items identified
with a message or
black dot
Examples
Insulin
Some Vaccines
Trace elements
Coumadin
Nicotine
Miscellaneous
Rx Spill Cleanup
Debris
Rx in Syringe –
Discharge into
gauze, gauze in
container, syringe
to SHARPS
Place into BLACK
CONTAINER
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Compatible Hazardous Rx Waste
• Identified with the AcuDose message or MAR message in the Label
Comments, and/or on the label
• The Rx and containers having contact with Rx (vials, IVs & Tubing, etc.)
placed into container (full, partials or empty)
– Specifically includes Coumadin and Nicotine Waste and Packaging
• Place in BLACK Container
“Place in BLACK
Container”
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Incompatible Rx
Waste
“For Disposal
Return to
Pharmacy”
INCOMPATIBLE HAZARDOUS
RX WASTES
Incompatible Rx
Wastes Require
Segregation to Meet
DOT, Safety &
Disposal
Requirements
Place in zip lock bag
Aerosols
Inhalers with
canister
Oxidizers (Examples)
Unused Silver
Nitrate
Corrosives
(Examples)
L-cysteine (in
pediatric TPN)
Corrosives
(Examples)
 Botox
Place into a BAGGIE
and RETURN TO
PHARMACY
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Incompatible Hazardous Rx Waste
• Identified with the AcuDose message or MAR message in the
Label Comments, and/or on the label
• Rx Waste that cannot be collected in the same container due
to EPA and DOT regulations
– Examples: Aerosols (mouthpiece removed), Corrosives (Robinul),
Oxidizers (unused silver nitrate sticks), Toxins (Botox)
– Bag and place in Incompatible Container
Place in Baggie
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“For Disposal Return to
Pharmacy ”
Bulk & Trace Chemotherapy Rx
Waste
A Chemotherapy
Rx and
containers that
are NOT empty
CHEMOTHERAPY WASTE
Bulk Chemotherapy Waste (Black)
Trace Chemotherapy Waste (Yellow)
Chemo Agents
IVs with Residual
Chemo Agents
Chemo Spill
Cleanup Debris
Vials with
Residual Chemo
Agents
Tablets, caps etc
Place into BLACK
CONTAINER
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Chemotherapy Rx
and containers
that ARE empty
Empty Syringes
Gowns with
chemo small
amount of
contamination
Gloves
Goggles
Wipes
Empty IVs /
Tubing
Empty Vials
Place into YELLOW
CONTAINER
TRACE Chemotherapy
• “Trace” Chemotherapy Waste is any EMPTY
Chemotherapy Container (YELLOW)
– Empty IVs and tubing
– Syringes
– Non-contaminated PPE
• Gowns, Goggles, Gloves
• Wipes
– Place these items into the YELLOW Container that is currently
being used
• Yellow Containers will be located on units that
consistently use Chemotherapy items
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BULK Chemotherapy
• “Bulk” Chemotherapy Waste is any chemotherapy Rx
that is NOT empty
– Non-empty containers holding free liquid (vial, IV bag,
tubing)
• Oral medications – Patient refused, medication dropped, etc.
• Discontinued Rx – Patient reaction, partial IV
– Overtly contaminated garments and spill clean up material
• Gowns, Goggles, Gloves
• Spill cleanup (Rags, Wipes, Towels)
– Place into BLACK Container
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Non-Hazardous
Rx Waste
No Messaging
Not Labeled or
Identified as
Non-Hazardous Rx
by Pharmacy
NON-HAZARDOUS RX WASTE
Collect Full and
Partially Full Rx
Containers
Examples
•Antibiotics
•Lidocaine
•Marcaine
•Heparin
Miscellaneous
Place into BLUE
CONTAINER
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Non-Hazardous Rx Waste
• Identified with the AcuDose message or MAR message in
the Label Comments, and/or on the label
• Managed by placing waste into BLUE Container
– Majority of Rx will be Non-hazardous - therefore no label
NO
LABEL or
IDENTIFIER
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Regular Trash
• Items that can be disposed of in the regular Trash
include:
– Outside packaging and package inserts
– Cardboard
– Plain IVs and Tubing
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GENERAL REQUIREMENTS
Containers – Closed and Labeled
Movement of Full Containers
Spill Response
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Container Requirements
• The hazardous waste
containers (Black) must be
stored in a closed and
labeled
– Close the containers when not
using them
– The label must have at least
the words “Hazardous Waste”,
a description of the contents,
and the date that the container
was filled (completed by
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PHARMACEUTICAL HAZARDOUS
WASTE
START DATE _____________________________
CONTAINER FULL DATE ___________________
PHARMACEUTICAL HAZARDOUS
WASTE
START DATE _____________________________
CONTAINER FULL DATE ___________________
Movement of Containers
• Rx Waste Containers must be under the control of the
staff; therefore they will be generally located in
centralized areas in each unit such as the Soiled Utility
Rooms or in or near Med Rooms or Procedure Rooms
• The full containers will be managed like the Sharps
Containers and picked up by Stericycle Technician
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Spill Response
• Refer to facility Spill Response Policy, which
includes the following:
– Call Spill Team
– Secure Area
– Identify Material & get MSDS
– Contain and Clean-up as directed by Spill Team
• Spill Kits, Absorbents
– Dispose of Hazardous Clean-up Materials
Properly
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• Hazardous Waste Container