For the past three years, PP&P has been tracking the actual pharmaceutical waste practices of hospital pharmacists nationwide. This past December’s Going Green issue reported on macro trends such as budget allocations, waste equipment purchases, and staff training approaches. In addition, we have continued to monitor how difficult-to-dispose products are being handled. Clearly, controlled substances fall into this challenging category given their regulatory duality wherein the EPA requires a non-recoverable disposal (a term which remains amorphously undefined), while many states simultaneously forbid the disposal of pharmaceuticals directly into water systems ill-equipped to filter these pharmaceuticals.

Unfortunately, controlled substances are not the only pharmaceuticals that fall under the difficult-to-dispose classification. Disposing of the flu vaccine, for example, provides a challenge, as many health systems do not account for the preservative thimerosal, which is present in some formulations, when designing their waste plan. Added as a preservative, thimerosal (a mercury derivative) is hazardous under the EPA’s toxicity characteristic. As such, any product that contains a mercury concentration of at least 0.2 mg/liter should be disposed of as hazardous waste. This requirement encompasses all full or partially used multidose vials of flu vaccine. In addition, because thimerosal was used in the manufacturing process for Novartis’ unit dose 0.5 mL syringe for 2011-2012, this product also must be disposed of as hazardous waste.¹

Awareness of the effect of the preservative in determining the proper waste stream has grown within pharmacy of late. Two years ago, hospitals pharmacies were more likely to dispose of their flu vaccines via a red sharps container rather than using a RCRA-hazardous container. Keep in mind that the red sharps container is the correct waste route for the nasal spray version of the flu vaccine as it is derived from live attenuated versions of the virus and does not contain thimerosal. In two years’ time, those following proper disposal methods have grown from just a third to half of all hospitals nationwide. Nonetheless, this progress has been relatively slow; 49% of all facilities in the US are still using inappropriate methods to dispose of their bulk flu vaccines containing thimerosal. 

Every health system’s commitment to compliant waste management must include a plan for disposing of all full or partially used vials of the flu vaccine containing thimerosal. Given the fluctuations in demand surrounding this product, it is irresponsible to not have a fully compliant disposal plan in place. Consider dedicating the same forethought to your flu vaccine disposal plan as you currently dedicate to your flu vaccine ordering calculations. When you sit down to plan your 2012-2013 flu vaccine ordering, this is an opportune time to also develop your flu vaccine disposal plan.

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Reference

1. Pharmecology presents disposal guidelines for the 2011-2012 flu vaccines. http://www.pharmecology.com/pedd/jsp/static/a6_news_20110912.jsp. Accessed 2-1-12.

Deanne Halvorsen is the editorial director of Pharmacy Purchasing & Products and can be reached at dhalvorsen@ridgewoodmedia.com.