NSWMA Healthcare Waste and Landfill Institutes Comment on Best Management Practices for Unused Pharmaceuticals at Health Care Facilities

FOR IMMEDIATE RELEASE
November 18, 2010
Contact: Thom Metzger, 202-364-3751 or tmetzger@envasns.org

WASHINGTON, D.C. – The National Solid Wastes Management Association (NSWMA) Healthcare Waste Institute and Landfill Institute recently submitted comments to the United States Environmental Protection Agency (EPA) regarding its draft guidance, "Best Management Practices for Unused Pharmaceuticals at Health Care Facilities," published in the Federal Register in September 2010.

"Currently, there are multiple agencies at the federal and state levels that play a role in the management of unused pharmaceuticals, and regulations in this area often overlap or are in conflict," said Alice Jacobsohn, director of NSWMA’s Healthcare Waste Institute and Landfill Institute. "We are pleased to have the opportunity to offer comment to EPA as it advances a more streamlined path."

In its comments, NSWMA recommends that any new EPA directive (1) maximize the protection of healthcare and waste management workers and the public; (2) simplify advice on protective disposal; and (3) maintain consistency with existing regulatory requirements. NSWMA also notes how the draft EPA guidance could be greatly enhanced and simplified by separately addressing the recommended best management practices for different healthcare sectors (e.g., hospitals, clinics/physician officers, and long-term care facilities), not limiting protective available options, and more completely discussing the complications of dual substance management.

Specifically, NSWMA recommends that when directing pharmaceutical waste either to a hazardous or solid waste incinerator for disposal, EPA not ignore current healthcare waste management options, including infectious substance and regulated medical waste hauling and disposal. Furthermore, NSWMA suggests that EPA consider mail-back disposal options for small doctors’ offices, especially those located in remote areas.

In regards to "dual wastes," where unused pharmaceuticals must be managed as a hazardous waste and infectious substance or regulated medical waste, NSWMA recommends that EPA's guidance make clear that all regulatory requirements for each waste type be met. NSWMA also recommends that EPA create a separate dialogue on how to deal with these regulatory issues among federal and state agencies.

Finally, regarding EPA's recommendation that unused pharmaceuticals be mixed with an undesirable material before disposing of them in landfill to dilute them and prevent their illegal distribution, NSWMA's comments explain that such efforts neither neutralize the pharmaceuticals nor prevent their exposure to the environment. NSWMA states that these materials must be segregated to allow for special handling by landfill workers.

Regarding these recommendations, Jacobsohn said, "NSWMA Healthcare Waste Institute and Landfill Institute appreciate EPA's efforts to address important issues, and we look forward to discussing our comments further with EPA."

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NSWMA – a sub-association of the Environmental Industry Associations – represents for-profit companies in North America that provide solid waste collection, recycling and disposal services, healthcare waste management, or provide professional and consulting services to the waste services industry. NSWMA members conduct business in all 50 states. The Landfill Institute and Healthcare Waste Institute (HWI) are policy-making groups within NSWMA. HWI members transport, treat, and dispose of healthcare waste; manufacture or distribute products used to manage healthcare waste; or provide consulting services to those involved in this type of business. Landfill Institute members are owners and operators of landfills and consultants, engineers, and attorneys providing services to landfills.