Many drugs of concern to EPA and the Center for Disease Control and Prevention (CDC), including hormones, antibiotics, antidepressants, antihypertensives, and other potent drugs, are not caught by the current hazardous waste regulations.
The RCRA hazardous waste regulations have not been substantially updated since their inception in 1976 and as a result have not kept pace with drug development. In addition, these regulations were not developed with a hospital setting in mind. As a result, approximately 10% of the drugs that are not technically subject to
the hazardous waste regulations are equally hazardous under RCRA criteria.
Considering that only 5% of drugs are regulated under RCRA, the remaining 95% of drugs may be “hazardous” using both traditional toxicity measures and newer criteria, such as antibiotic resistance, endocrine disruption, and developmental disruption due to prenatal or early postnatal exposure.
Therefore, pharmaceuticals that are not technically RCRA hazardous waste when discarded should be analyzed for their potential to cause harm to human health and the environment.
Best management practices encourage managing drugs that are equally harmful as hazardous waste when discarded and managing all other drug waste through incineration rather than drain disposal and landfilling.
Following best management practices is also good risk management. Recent activity by the EPA Office of Water has indicated their growing concern with drugs entering the ecosystem. In October, 2007, EPA published its Preliminary 2008 Effluent Program Guidelines Plan for public comment.
All of this attention should encourage healthcare facilities to move to best management practices for pharmaceutical waste disposal.
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