Compliance with the new EPA Pharmaceutical Rule, “Management Standards of Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine,” begins with a two-step process.
- First: categorize all the waste your long-term care facility (LCTF) generates.
- Second: determine if any of the waste is considered hazardous waste (HW). That includes pharmaceutical waste, which is by far the largest category of waste that an LTCF must address when making an HW determination.
That second step may seem simple, but consider the sheer number of drugs – over 300,000! – listed in the US Pharmacopeia. Between 6% and 9% of them would be classified as hazardous waste under the new rule and require proper handling. Even on the low end, that’s still at least 18,000 drugs! P-listed, acutely toxic HWPs carry more stringent regulations. In some states, Nicotine is considered a P-Listed drug.
Our white paper discusses steps that LCTFs need to take to ensure compliance.
Every State Must Comply by July 1, 2021
The new EPA rule went into effect on August 21, 2019 in eight states. All other states have until July 1, 2021 to adopt Subpart P of the rule. This rule affects how long-term care facilities make hazardous waste determinations and dispose of hazardous waste pharmaceuticals.
Our white paper describes how the new rule revises management standards for the management of “Hazardous Waste Pharmaceuticals” (HWPs) for all healthcare facilities, including LCTFs, as defined by the rule. It’s consistent and applicable for the eight states already covered:
- New Jersey
- South Dakota
We encourage all healthcare facilities in the remaining states to consult with their state regulators for guidance and deadline information for statutory compliance. All states must be in compliance by July 21, 2021, but your state may set earlier compliance targets.