Though EPA is proposing pharmaceutical waste changes, pay attention to your state

Pharmaceutical waste, as they say in the industry, is a very sticky wicket. There is certainly a great deal of anticipation that the RCRA restrictions (nice alliteration, eh?) will be relaxed to a degree that is most favorable to hospitals when it comes to this waste (see the January 29 Hospital Safety Connection for a brief rundown of what’s happening).

Basically, universal waste includes such items as batteries, pesticides, mercury-containing equipment like thermometers, and probably the most common universal waste found in healthcare, fluorescent lamps. The EPA wants to add certain pharmaceutical wastes to the universal waste category.

The EPA has posted online information about universal waste and there’s a link down towards the bottom of the page that will direct you to individual state sites.

All that said, I’d like to be able to tell you it’s fine to wait for the EPA proposal to run its course, but I know in my heart of hearts that even if the feds adopt the classification of certain pharmacy wastes as universal, you might still run afoul of the state environmental protection folks.

My best advice would be to contact your state environmental regulators (perhaps through a surrogate) and inquire about the process, without, of course, indicating that your program is still a little ways away from perfection. Strictly speaking, until the EPA change officially happens, you’re still at risk from a compliance standpoint.