Every facility generating medical waste must adhere to specific legal requirements for its disposal. A crucial aspect is documented proof that pharmaceutical waste has been lawfully and correctly disposed of. If your facility is audited and this evidence is lacking, you could face substantial fines or worse.
Many medical waste generators we speak to are unaware that not all waste management companies are licensed to transport hazardous pharmaceutical waste. When using such companies, their waste may not be disposed of properly. Furthermore, even when transporting non-hazardous pharma waste, a permit from the State Board of Pharmacy is still required.
Are you certain that your medical waste transportation company is handling your facility’s pharmaceutical waste appropriately? It’s essential to be confident, as any liability for improper disposal lies with you, the waste generator, not the company hired for disposal. A comprehensive cradle-to-grave regulated waste management program, including pharmaceutical waste certificates of destruction and manifests, ensures your facility’s compliance with RCRA legislation requirements.
Understanding Pharmaceutical Waste Manifests
Proper waste management is a vital component of safe pharmaceutical handling. The risks associated with incorrect disposal of medical drugs and chemicals are well-documented and include:
- Contamination of groundwater, drinking water, and plant life due to leaching into the environment.
- Health issues in the community.
- Increased likelihood of drug misuse.
A waste manifest is required for all regulated medical waste, including non-hazardous pharma waste. The Hazardous Waste Manifest System, established by the EPA and U.S. Department of Transportation, is utilized for hazardous pharma waste. It mandates that all waste generators who transport or offer hazardous waste for off-site treatment and disposal, including pharmaceuticals, maintain a pharmaceutical waste certificate of destruction and manifest.
The hazardous waste manifest document accompanies RCRA-designated waste from your facility to its designated hazardous waste treatment, storage, or disposal facility. The manifest, completed during service, identifies:
- Your facility as a healthcare waste-generating site.
- What is being picked up (number and type of containers).
- The transporter responsible for off-site transportation.
- The destination for hazardous waste treatment, storage, disposal, or recycling.
As a generator of pharmaceutical waste, you bear full responsibility for the accuracy and completeness of the information on the manifest, which is signed by you and the driver.
What Should Be Included in a Certificate of Destruction
Your facility is accountable for maintaining compliance with RCRA regulations from initial generation through transportation and final disposal. A certificate of destruction is just one record that must be completed and submitted when shipping hazardous waste. Alongside the hazardous waste manifest, it helps track your pharmaceutical waste, confirms proper disposal, and informs you of your pharmaceutical waste’s destination.
A certificate of destruction should contain:
- The waste generator’s name, address, and other relevant information (your facility).
- A work order number.
- An invoice number.
- The date the pharmaceutical waste items were received.
- A detailed description of all items transported for incineration.
- A legal statement from the waste management company, confirming compliance with state and federal, DOT, EPA, and Department of Toxic Substance Control (DTSC) laws.
- An accuracy statement verifying the certificate of destruction’s information is accurate.
- The certified signature of an authorized pharmaceutical waste management and transport company representative.
- The date the certificate was issued to you by the hazardous waste disposal company.
Your staff should be aware that pharmaceutical waste cannot be taken to a landfill. To ensure your facility properly manages hazardous waste streams, specific state and federal regulations must be met, including incineration of all bulk and trace chemo waste, regardless of quantity—even trace amounts must be incinerated.
Managing Hazardous Waste Pharmaceuticals
Whether you oversee a clinic, medical research lab, veterinary hospital, nursing home, or another facility that produces pharmaceutical waste, it’s your responsibility to be familiar with and adhere to applicable federal and state laws.
Collaborating with an experienced, insured, and adequately licensed hazardous waste transporter that offers both a certificate of destruction and a manifest provides the reassurance you need to know the job is done legally and correctly.
If you’d like to learn more about the importance of a pharmaceutical waste certificate of destruction and manifest or discuss which pharmaceutical waste documents should be retained, contact RxRS today. As a licensed contractor for the disposal of hazardous and non-hazardous pharma waste, we can guide you on whether your facility is complying with and maintaining all regulatory standards.
