Implementing a strategic pharmaceutical waste management program may result in several benefits, including increased environmental stewardship, regulatory compliance, simplified workflow, and potentially, cost savings. Conversely, disposing of waste without a well-planned strategy may expose a hospital to citation from a regulatory agency as well as unnecessarily increasing the pharmaceutical burden on groundwater and on the environment as a whole. Although motives for implementing a pharmaceutical waste management program will vary for each health system, ensuring TJC and other regulatory body compliance, decreasing waste costs, and promoting a green culture and environmental footprint are often the greatest motivators for hospital and pharmacy leadership. 

Selecting a Waste Management Partner
Choosing a waste management vendor is one of the initial considerations to institute an effective program. If your hospital already partners with a vendor to manage other waste streams, it may be prudent to inquire if that vendor offers a robust pharmaceutical waste management program as well. Extending an existing contract may provide a smooth transition to a new service. Factors to consider when choosing a vendor include the comprehensiveness of their program, including whether they provide implementation assistance, a staff education component, ongoing monitoring, and auditing support post-implementation. 



Implementing the Program
If your health system spans multiple hospitals, it may be wise to roll out the waste program at one of the smaller facilities first, which will allow time to make any required adjustments before beginning implementation at the larger facilities, which often have a more complex formulary to manage. One of the first steps in each hospital’s planning stage is to evaluate the formularies and assign hazard classifications to every medication. After the formulary has been reviewed, identify the number of bins required for every area where pharmaceuticals are delivered and administered, then determine the ideal locations for the various bins. Hazardous medications, including toxic drugs, flammables, and corrosives, require strict segregation, so it may be prudent to convene a multidisciplinary group to evaluate the volume of these medications used in each department and determine how to manage them appropriately. The regulations and guidelines governing the disposal of chemotherapy and narcotics also must be evaluated. In addition, empty containers, containers containing residual medication, medications that have been combined, drugs in a syringe or needle, and medications that may be comingled with blood or body fluid require different disposal methods and must be evaluated carefully. 

Sorting the various types of waste into the correct containers to ensure they are disposed of properly can reduce the health system’s environmental footprint, ensure regulatory compliance, and cut costs as a result of the appropriate identification of waste stream disposal requirements.  

Developing a Policy and Procedure
Because the pharmacy, nursing, radiology, anesthesia, respiratory, and environmental departments handle different medications and thus require diverse guidance on compliant waste disposal, separate policies and procedures (P&Ps) may be required to guide these processes. These P&Ps must include information detailing how each type of medication waste should be disposed of, the responsibilities of each staff member, and what education must be provided to new hires in each area and to staff on a yearly basis. 

Staff Training
A robust staff training program—including staff meetings, face-to-face and online education, and posting flyers in each waste disposal area to remind nursing of proper disposal for each medication—should be initiated for all employees handling pharmaceutical waste. In addition, consider requesting that your waste vendor place a representative on campus for the first days or weeks after rollout to provide education and answer any questions that arise. Challenges that are identified during this critical period can be addressed immediately, and processes can be adjusted after the initial implementation on an as-needed basis. 

Evaluating Metrics
Developing metrics to track program success and staff adherence is valuable to identify areas of improvement. A vendor will typically remove containers when they are three-quarters full to avoid the risk of staff contact with discarded medication, and the containers may be sorted at their facility to evaluate each department’s compliance with sorting procedures. The vendor should note any sorting errors and forward this data back to our hospital. This information must be communicated to the pharmacy manager, nurse manager, safety officers, and the environmental services department. Review of this information identifies potential error trends in certain departments and permits targeted reeducation for employees in these areas. Request that your vendor report error rates weekly, which will allow timely resolution. Pharmacy must report overall error rates to administration on a regular basis; many hospitals report this data quarterly. 

Refining Processes 
Despite careful planning and decision-making, it is unlikely that hospital leadership will anticipate every challenge that may develop post-implementation. After the program has been implemented, it may be necessary to reevaluate the locations of various waste containers, as well as the frequency of pickups. Patient medication volume may be higher on some days of the week than others, so the frequency of pickups may need to be adjusted on those days. These changes are especially important given the higher costs that may be levied by your vendor for overfilled bins, so increasing pickup frequency will significantly reduce these charges. In addition, adjusting the location of bins may become necessary to streamline workflow. During the implementation period, seek feedback from end users on how to improve processes; evaluation of their suggestions will identify ideal placements for containers. 

Results of Program Adoption
One of the most significant benefits of initiating a pharmaceutical waste management program is the peace of mind that results from the knowledge that pharmaceutical waste is disposed via appropriate waste streams, thus ensuring a robust environmental stewardship focus. In addition, partnering with a vendor that provides comprehensive auditing of staff sorting compliance may result in cost savings due to appropriate waste removal.

Deanne Halvorsen is the editorial director at Pharmacy Purchasing & Products magazine. She can be reached at DHalvorsen@ridgewoodmedia.com.