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Hospital pharmacies combined.pdf

Certain hospital wastes are regulated under Part 111, Hazardous Waste Management, Michigan CompiledLaws (MCL) 324.11101 et seq. (Part 111) of Michigan’s Natural Resources and Environmental ProtectionAct; 1994 PA 451, as amended, and Subtitle C of the Resource Conservation and Recovery Act of 1976,as amended (RCRA), and any administrative rules or regulations promulgated pursuant to these acts.
Many hospitals may not be classifying their wastes appropriately to assure that solid and hazardouswastes are disposed of in compliance with state and federal regulations. This bulletin has been preparedto provide guidance to hospitals, with an emphasis on hospital pharmacies to correctly classify,containerize, label, and dispose of waste medicine.
The bulletin applies to hospitals which are regulated hazardous waste generators under RCRA and Part111. Hospital facilities generating more than 100 kilograms of hazardous waste (or 1 kilogram of P-listedwaste) per month are regulated. Hazardous waste from pharmacy departments normally represent asmall fraction of the hazardous waste generated by hospitals. Xylene from the pathology lab, paint wastefrom maintenance, silver waste from the processing of x-rays, some x-ray films, fluorescent light bulbs*and batteries* are other potential hazardous waste streams generated by hospitals. If hazardous wastegenerated by the hospital as a whole is greater than 100 kilograms per month (this is equivalent to 220pounds or to about the weight of 27 gallons of water), or if 1 kilogram of a P-listed waste is generated, anyhazardous waste generated by the pharmacy will also be regulated. Although regulated hospitals are thefocus of this bulletin, much of the guidance will be applicable to smaller hospitals as well.
The table (see attached) contains examples of elements and compounds that hospital pharmacies oftengenerate and, when disposed of, may need to be handled as hazardous waste. Many of the compoundsare medications and, if returned to the manufacturer, wholesaler or other reverse distributor, are notconsidered a waste to the hospital. USEPA and DEQ have recognized that a market mechanism is inplace that provides for the return of medications (including those outdated, damaged in shipment, recalled,or which have FDA approval repealed) to the manufacturer or third party. The manufacturer or third partymakes the decision on disposal of these medications, and the medications will not have to be declared aswastes to the hospital.
Compounds from the table with a P or U waste code would be a hazardous waste only if they are the soleactive ingredient in the material being disposed. For example, if an IV dose of chlorambucil is preparedand not used and must be disposed of, this material must be disposed of as a hazardous waste. If twoactive ingredients are used in the medication, however, the material need not be classified as a hazardouswaste. What often occurs is that some compounds that are hazardous waste when disposed of are beingdisposed of as medical waste. Medical waste transporters and disposal facilities may not be licensed tohandle this waste. Those materials identified as hazardous waste are required to be containerized,labeled with the MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY John Engler, Governor • Russell J. Harding, Director words “hazardous waste,” and the waste numbers, and marked with the date accumulation began. Disposal of the wasteshould normally occur within 180 days of the date accumulation began (90 days for hospitals which generate over 1000kilograms of hazardous waste or one kilogram of P-listed waste per month).
The flow chart (see attached) is a waste classification aid for the hospital pharmacy. The first diamond illustrates the return ofmedications. In the second diamond are the list of U and P code wastes. The table (see attached) is a list of elements andcompounds known to be used by hospitals but may not be complete. The third diamond, on the flow chart, requires anevaluation of whether the material exhibits a characteristic of hazardous waste. Characteristics of hazardous waste includeignitability, corrosivity, reactivity and toxicity as defined in Part 111. Many materials may contain alcohol and be ignitable.
Materials containing zinc, lindane or barium may be toxic. Materials which are strongly acidic or basic may be corrosive. Ifthe material is found to exhibit a characteristic of hazardous waste, the medication should be handled as a hazardous waste,and the waste code for that characteristic applies.
If the material is not a listed or a characteristic hazardous waste, the material should be disposed of in compliance with thefollowing: Part 115, Solid Waste Management; Part 121, Liquid Industrial Wastes, of Michigan’s Natural Resources andEnvironmental Protection Act, 1994 PA 451, as amended (Act 451); and The Michigan Medical Waste Regulatory Act of1990, Act 368, P.A. 1978, Part 138, Medical Waste.
* Wastes such as fluorescent light bulbs and batteries may be managed as universal wastes - request a copy of the WasteManagement Division Universal Waste Fact Sheet from either your local DEQ District Office or by calling the EnvironmentalAssistance Division at 1-800-662-9278.
This document was prepared on December 11, 1997. Be advised that subsequent law, rule and otherinformation may change the applicability of this document. This document is a summarization of stateand federal rules and regulations and is not to be used as a substitution for the actual regulations. Thisdocument is not intended to convey any rights to any parties nor create any duties or responsibilitiesunder law. This document and matters addressed herein are subject to revision.
The Michigan Department of Environmental Quality (MDEQ) will not discriminate against any individual or group on the basisof race, sex, religion, age, national origin, color, marital status, disability or political beliefs. Questions or concerns should bedirected to the MDEQ Office of Personnel Services, P.O. Box 30473, Lansing, MI 48909.
Flow chart for the evaluation of Waste Pharmaceuticals
Applicable to small quantity and fully regulated generators of hazardous waste * Material is a listed hazardous waste and may also be hazardous for any characteristics that might apply.
Material should be disposed of in compliance with (1) a chemical on table 205b of R299.9225; (2) a chemical on table 205c of R299.9226; * The material is a characteristic hazadous * Material is a liquid industrial waste and Examples of hazardous wastes that might be encountered by hospital pharmacies.


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