By Charlotte A. Smith and Gregory Gicewicz
To pass inspection, the Healthcare Laundry Accreditation Council (HLAC) requires that a laundry facility meet specific standards related to its handling of pharmaceutical waste. These wastes are highly regulated. The regulations can oftentimes be challenging to understand, even for the expert. Recently, HLAC and the American Reusable Textile Association (ARTA) co-sponsored a webinar, “Managing Pharmaceutical Waste: What Healthcare Laundry Facilities Need to Know.“ This is the second of three articles that are intended to provide a recap of the highlights presented in the webinar. For more information, please refer to the full presentation (available as a PDF) found here. (http://www.hlacnet.org/articles-reports-presentations)
In Part I of this article found here, we discussed the basics of handling pharmaceutical waste received in the healthcare laundry. Now, we’ll weigh-in on the critical decisions laundry personnel need to make regarding the management of these items.
Who ‘Owns’ the Waste?
Can the laundry send the drug waste back to the facility? The simple answer is, “no.” There is no legal pathway available to return these drugs to the facility where they originated. What you can do is remind all your customers of the need for continuous training of employees to ensure that all drugs and drug-related items, such as empty or parietal IVs, vials, etc., are disposed of properly during and after procedures and medication administration.
Will the laundry take “ownership” of the drug waste? This is a more complex question so let’s explore your options:
If the laundry takes ownership of the drug waste, the business becomes the generator of the waste and must either
- Make a waste determination whether or not the waste is a hazardous waste
- Or, manage, manifest, and ship all pharmaceuticals waste as a hazardous waste.
In either case, the healthcare facility should be charged for all related costs.
There are additional regulations that apply and must be understood but are not terribly onerous at the level of generation that is involved:
If the laundry does not take ownership of the waste, the laundry would do the following:
- Notify the hospital that it has received pharmaceutical waste
- Determine if the waste is a hazardous waste
- If so, store the pharmaceutical waste in an appropriate container in a secure area
- Ship a.s.a.p., using a hazardous waste transporter under a manifest listing the healthcare facility as the generator
- The transporter would have to fully understand the healthcare facility is the generator and prepare all the shipping documents accordingly
- The cost per pick-up would be very high on a per pound basis.
Non-hazardous pharmaceutical waste could be accumulated from multiple facilities and a fee charged to the healthcare facility prorated for their contribution. This involves a great deal of recordkeeping along with the waste determination requirement.
When You Take Ownership
Let’s assume that you decide to take ownership of the waste, which may make the most sense from both a regulatory and competitive perspective. What does that involve and how can you manage these waste streams most effectively?
There are three basic pharmaceutical waste streams:
Trace chemotherapy waste:
- Any non-drug item found in the “chemotherapy” laundry bags
- Any empty vials, IV bags, syringes/needles etc. found in the “chemotherapy” laundry bags
- All disposable personal protective equipment worn while handling “chemotherapy’ laundry bags
- Dispose into either a hard plastic yellow waste container or into a yellow plastic hamper bag labeled as chemotherapy and biohazardous waste.
Any full or partial vials, ampules, IVs, etc. found in any soiled laundry should immediately be placed into a ziplock bag with the name of the facility, if known, and given to a manager for additional research as described below.
Hazardous pharmaceutical waste:
- Any vials, IV bags, etc. containing drug found in the “chemotherapy” laundry bags should be placed into a ziplock bag, given to a manager, and either verified as hazardous waste or placed immediately into the black hazardous container
- To verify if a drug is a hazardous waste, the laundry should have access to some type of database that can provide this information for each drug product
- The manager should take a photo of the drug as documentation, then look up the drug in the database and, if hazardous, log the name and hazardous waste code, if appropriate, into a manual or electronic recordkeeping system, such as Excel. This will need to be provided to the hazardous waste vendor initially to set up a waste profile
- Place the hazardous drug waste into either a black container labeled as both “Flammable” and “Toxic” or into a container labeled as “Aerosol,” if it is a pressurized canister.
Non-hazardous pharmaceutical waste:
- If the manager has determined the drug is a non-hazardous waste, it should be photographed, documented into the non-hazardous drug log, and placed into either a white or blue container labeled as Non-hazardous Pharmaceutical Waste; there should NOT be a biohazardous label on this container; some states, such as California, require additional labeling
- The laundry always has the option of managing the non-hazardous pharmaceutical waste in the black container as a hazardous waste.
Here’s how to store all three types of pharmaceutical waste
Yellow trace chemotherapy containers/hamper bags:
- Receiving employees should be trained to manage trace chemotherapy waste in the area in which the items will be found
- A hard plastic yellow container should be available and possibly a yellow hamper bag if a significant amount of disposable PPE and other “soft” items are being received in the chemotherapy laundry bag
- If possible, the healthcare facilities that routinely include these items should be contacted and encouraged to remove these items before wrapping and shipping the soiled linens
- Including a handling and processing fee is appropriate if the problem persists
- When full, the containers and hamper bags should be sealed and stored with any red regulated medical waste containers.
Black hazardous pharmaceutical waste containers:
- The black container should be stored in a secure location
- The date waste is first placed into the container should be noted and a log kept of drugs placed into the container; this is the same log noted above
- Some states require additional information and labeling, so be sure to check your state’s requirements for “Conditionally Exempt Small Quantity Generators,” or “Very Small Quantity Generators” (this is the new name for this category that will be adopted by all states within the next two years).
Blue/white non-hazardous pharmaceutical waste containers:
- If you do decide to segregate non-hazardous pharmaceutical waste, it can be stored in the same secured area as your regulated medical waste and trace chemotherapy waste.
In our final installment, we’ll wrap up by discussing in more detail which vendors are appropriate for each waste stream, how to identify and manage DEA controlled substances (drugs of abuse), and what your responsibilities are with respect to protecting your employees from inadvertent exposure to pharmaceutical waste.
ABOUT THE AUTHORS
Charlotte Smith is Senior Regulatory Advisor, PharmEcology Services for WM Sustainability Services, Houston, TX.
Gregory Gicewicz is past president of HLAC and owner/operator of the healthcare laundry Sterile Surgical Systems, Tumwater, WA.
HLAC Inspector Thomas “Tony” Fitzgerald contributed to the original presentation for the webinar.
Image: (c) Can Stock Photo / Lopolo
