When the Resource Conservation and Recovery Act (RCRA) was initially signed into law in 1976, it largely and rightly focused on the generally easily distinguishable chemical wastes generated by industrial facilities. Where most waste streams generated by the average industrial facility are predictable, those from hospitals and healthcare facilities are far more varied in type and amount. Additionally, the protocol for identifying, managing and disposing of them properly can be especially complex. To help address the complexity of these regulatory compliance requirements for one particular hospital and healthcare facility waste stream — pharmaceuticals — the United States Environmental Protection Agency adopted on August 21, 2019, theManagement Standards for Hazardous Waste Pharmaceuticals.Below are just a few of the major changes taking effect that are intended to provide greater clarity and consistency in managing hazardous waste pharmaceuticals across states:
Waste Determinations
危险废物药品由在典型的医院或医疗保健设施中工作的许多不同员工产生。These pharmaceutical wastes can be found in forms such as tablets, pills, liquids, lozenges, creams, IVs, transdermal patches, etc. A fundamental baseline RCRA responsibility requires that the generator of these wastes (i.e., the hospital and/or healthcare facility) make and retain a record of their waste determinations. Essentially, each and every pharmaceutical waste or waste stream needs to be evaluated to determine if it meets the definition of a Hazardous Waste Pharmaceutical or not. A major portion of the new RCRA rule change attempts to clarify aspects of the waste determination procedure for pharmaceuticals, however, this process is still beyond the expertise of most healthcare facility employees. It also is very important to note that the generator needs to apply this waste determination process to all of the hundreds (if not thousands) of chemical wastes and waste streams generated by their laboratory, plant operations, imaging, sterile processing and all other departments in their facility.
发电机状态
根据新的规则危险废物药物（包括急性危险废物，否则被称为P榜上市废物）在符合新规则时管理时不会符合发电机状态。通过减少合规要求，这一变化将极大地利用医院和医疗保健设施。然而，重要的是要注意，来自医院或医疗保健设施等其他地区的危险废物每月卷，如易燃物，腐蚀，溶剂和其他非药物危险废物，仍将用于确定发电机状态。
污水禁令
2019年8月21日横跨所有国家的额外变化是禁止禁止危险废物药物的禁令（请注意，“危险废物药物”术语在最近的RCRA修订中也定义）并适用于所有人不管发电机状态如何。该禁令不会影响非危害药物，也不受到毒品执法机构法规的控制物质。然而，EPA已经明确说明任何药物废物的污水都强烈劝阻。
These are just a few of the many changes the final Management Standards for Hazardous Waste Pharmaceuticals has set forth but you must note that regulatory changes from the EPA’s passage of the Hazardous Waste Generator Improvements Rule in 2017 are also coming into full effect across the country. Each of these federal RCRA changes and the corresponding (and often more strict) state and local hazardous waste regulations significantly impact hospital and healthcare facility hazardous waste generators.
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