1. Originally my impression was that based on USP 797 guidelines, inj chemo drugs only had be stored separately from the regulary stocked items, preferably in a negative pressure room.
Based on this hazardous drug presentation will we need to also consider separating all hazardous drugs discussed in this slide presentation.....that would almost necessitate another room to be able to store these additional items?
2. These regulations are limited to hospitals, big organization etc...but what is to prevent the regular citizen from discarding such wastes in their trash? Is this not a concern? About 2 years ago, I remember reading the FDA recommendations for discarding medications, lots of educational fliers and things I shared with my retail patients --- some of those instructions included mixing meds with used cat litter, etc and/or flushing meds down the toilet....has this information for the regular user been changed and who would enforce such regulations? Or has this even been considered?
My facility has purchased a manual titled McCoy's RCRA Unraveled 2010 Edition, supposedly used by the EPA as a reference. My Emergency Management Officer (who handles our hazardous waste) is interpreting the information in the manual related to syringes as extending to IV tubing and other delivery devices. I understand the syringe being generally empty upon administration of the medication to the patient, but the IV tubing may continue to contain a volume of med. What is the best practice for disposal of the IV tubing or IV bags? Our EMO tells me that "RCRA empty" does not apply to IV tubing because they are "delivery instruments" and not containers. Is this correct?
Here are some questions we received during the live webinar:
Chemotherapy
Q: Are there regulations for pass-through windows from the chemo clean room to the general pharmacy area (not ante room)?
Q: If an anti-neoplastic agent has specific storage requirements as a chemo agent, but is also flammable, what is your suggestion for storage?
Q: How should sites handle disposal of equipments used to prepared chemo drugs or IND drugs in the home setting?
Q: Have the requirements for chemo storage changed that now it requires negative pressure as well as separation?
Q: What is the best way to handle partial vial waste for chemotherapy after compounding? Pooling in a common container?
Q: We mix 46 Hour 5-FU Tx as the only chemo we prepare. Did I hear correctly at NHIA in Dallas that with our "low-volume" status of chemo, we can use the Pha-Seal product line, and thus are not required to have a negative pressure room/ set-up?
Q: What size of spill is appropriate for a chemotherapy spill kit? Also when is necessary to use a respirator? Is it recommended to have a hazmat team? If so when should they be called in to help with a spill?
Q: How should refrigerated chemo's be stored?
Q: So do we want to keep all hazardous drugs in a negative pressure environment or just chemos?
Compounding
Q: With a Class II BSC that is not ventilated to outside is used for compounding hazardous drugs, .is it recommended to provide a respirator to compounding tech to help minimize exposure to vapors that may be re-circulated in the room (should the HEPA filter not remove all airborn contamination)?
Q: Is it OK if we wipe vials before storing or should we really wipe them before getting them in the BSC?
Q: What would you recommend for facilities in states that do not recognize the use of ventilated CACIs and CSTDs in negative pressure cleanrooms as acceptable protection against HD contamination? Some regulations state only a Class II BSC is acceptable.
Q: Is it necessary to wear goggles during chemo preparation in addition to the glass shield on the BSC?
Q: For small volume hazardous compounding - we have a negative pressure CACI in a positive pressure room. Where should we store inventory? Can we have a fridge in the room?
Hazardous Drugs Q: In a hospital setting, how should we dispose of leftover morphine drips? What about expired IV antibiotics?
Q: If a facility does not have an in-house pharmacy and has pharmaceuticals that need to be destroyed (both hazardous & non-hazardous) and the vendor pharmacy does not want to accept them as a return, can this be placed in a compactor for destruction?
Q: What if you used 'Cat Litter' to destroy controlled drug, avoiding flushing down the drain?
Q: Just to clarify, even concentrated vials of Nitroglycerin (10 mL) are not considered RCRA?
Q: What is an approved way to dispose of narcotics? Is disposing of them down the sink acceptable?
Q: How should hazardous-controlled substances be handled such as testosterone and chloral hydrate?
Q: Do pharmaceuticals in blood fall under these regulations, or is this considered used and not hazardous waste?
Q: Can warfarin wrappers be disposed of in the red sharps container?
Q: Do you need to keep hazardous wastes in a secured area?
Q: Are electrolytes restricted or can they go down the drain?
Q: Can you please go over the appropriate process on handling non-chemo drugs (for example, Colchicine in tablet form and if needed, compounding into a suspension for vent patients).
Q: Cetacaine is an aerosol which is often used once on a single patient. There is a significant volume remaining. How should this be disposed of?
Q: Is there a list of non-vaccines that contain thimerosal?
Q: We have had a problem with hazardous drug breakage as received from distributor. Are distributors covered by the requirements or special rules, and are there standards for their packaging of hazardous drugs for delivery?
Q: Since we know that overwraps/boxes/packaging of drugs can be contaminated, how should that waste be disposed of?
Resources/Handling Hazardous Drugs Q: When is the next NIOSH list coming out?
Q: Where would a pharmacist look to determine whether an investigational agent is considered hazardous?
Q: Is there value in implementing a medical surveillance program for nurses and pharmacists exposed to hazardous drugs?
Q: Do you have any more information/resources regarding the testing of individuals that will be handling hazardous materials?
Q: Do you have any RCRA vendors you would recommend?
If the patient is incontinent, caregivers should be careful to wear chemo gloves when handling the disposable pads or diapers. Wrapping them in a plastic bag and disposing in the trash is most probably their only option. Keeping the medication safely stored out of reach of children, pets, etc. is obviously paramount. If unused drug is to be discarded for any reason, a medication take-back program would be optimal. If not available, they should refer to the guidelines offered by FDA and others to render them non-recoverable and dispose in the trash.
As an aside, if pets are being treated with chemotherapy, as is occurring more often, children must be taught not to let the pets lick them or otherwise play with them in a manner that could expose the children to the chemo. Any pet waste being collected should be managed as noted above.
05-09-201006:45 PM - last edited on 05-12-201011:29 AM by HeatherQ
These regulations are limited to hospitals, big organization etc...but what is to prevent the regular citizen from discarding such wastes in their trash? Is this not a concern? About 2 years ago, I remember reading the FDA recommendations for discarding medications, lots of educational fliers and things I shared with my retail patients --- some of those instructions included mixing meds with used cat litter, etc and/or flushing meds down the toilet....has this information for the regular user been changed and who would enforce such regulations? Or has this even been considered?
Thank you! I will respond to 2. Consumers are being advised not to flush any drugs except a short list of highly potent analgesics. Having said that, the only other good option are consumer take-back programs which are not available in many parts of the country. This is still an area that needs a great deal of attention. I recenlty learned that a county in the SF Bay Area had banned consumer meds in the trash, but admitted that enforcement was not possible at this time. But it's a step forward.
