03-24-2011 09:31 AM
Q: The requirement for special waste of pharmaceuticals that are aerosols is a state requirement only?
A: As noted, I know this regulation is in place for Nebraska. You will need to check with your state agencies on your states specifice regulations.
03-24-2011 09:32 AM
Q: Do Home Care companies have a responsibility for RCRA items dispensed to patient or is it the patient's responsibility?
A: The nice thing about RCRA it is for industry only (healthcare falls into this classification). Once it is in the publics hands they can dispose of RCRA/Controlled substances and aersols products anyway they want......at this point! RCRA does not cover items dispensed to patients.
03-24-2011 09:36 AM
Q: What are you doing about diversion of controlled substances if RCRA type med and needs to be placed in black container when nursing is "wasting" med ?
A: Great question. The only RCRA medication that is a controlled substance is chloral hydrate U-034. From the DEAs perspective it needs to have a witnessed waste and documented, as noted DEA doesn't care how you get rid of it as long as it is not recoverable. From a RCRA stand point the waste does need to be in a RCRA container. I would look to the sharps container folks for smaller RCRA containers which do not allow hands to get past the opening.
03-24-2011 02:58 PM
Just as a clarification on this thread...
Are you suggesting that drugs not P or U listed can be safely destroyed in the yellow chemo bins? The color coded slide in your presentation indicated that all partial vials of chemo are placed in the black bins. This is actually what we do.
03-25-2011 07:42 AM
You are correct ANY partial vials of hazardous drugs (that your site defines or if you use the NIOSH appendix A listing) should go into RCRA container. This is the BEST way to waste these hazards.
Thank you for clarifying.