Even with EPA’s proposed pharmaceutical waste changes, state regulations still matter

By: February 5th, 2009 Email This Post Print This Post

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 healthcare facilities when it comes to this waste (see the free article posted on the Hospital Safety Connection for a brief rundown of what’s happening and happening and how to comment on the proposal, which the EPA will accept until March 4).

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 is 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 change officially happens—the EPA expects the regulation to go into effect sometime in 2010—you’re still at risk from a compliance standpoint.


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