So you have just completed a course of medication for your beloved steed as directed by your veterinarian and you find yourself with a small quantity of pharmaceutical drug, say trimethoprim sulfa antibiotic, that is left over. You happen to notice that on the tack shed shelf next to that container of medication is a bottle of Bute pills that expired in March of 2002! Also on the shelf you spy a dusty, zip lock sandwich bag containing three, 20 gauge needles and syringes you used last spring. So what do you do with this "medical waste"? Dump it in the garbage? NO! Flush the drugs down the toilet?? ABSOLUTELY NOT! Neither of the above are legal in the state of California.Review the article below for timely information about what is legal and what is not regarding the handling of medical waste. For more information on home-generated pharmaceutical waste, visit the CVMA website, or www.calrecycle.ca.gov.
Home-Generated Pharmaceutical & Sharps Waste–What You Need to Know & Tell Your
Clients
by Grant Miller, DVM, CVMA Director of Regulatory Affairs
The issue of home-generated pharmaceutical and sharps waste has remained a recurring focus of the California legislature in recent years. In 2008, in an attempt to protect the public, a law took effect to make discarding home-generated sharps into the garbage or recycling illegal. The law further implemented measures to store sharps in approved containers and dispose of them at designated collection centers. In 2009, a law was also passed mandating state agencies to implement collection and disposal programs for home-generated pharmaceutical waste, in an attempt to avoid environmental contamination.
What is “home-generated” waste and how does it differ from “medical waste” generated in a veterinary practice? Veterinarians should delineate between home-generated waste and medical waste produced in their own practice, as their obligations in relation to each differ.
Home generated pharmaceutical waste – When a medical professional prescribes medication and sends it home with a client, there is a chance that not all of the medication will be used for one reason or another, and thus will remain in the client’s possession. This excess medication (which is often expired) is termed “home- generated” pharmaceutical waste.
Home generated sharps waste – Similarly, if a client is sent home with needles (to be used to manage diabetes, for instance), used needles become “home-generated sharps waste.” Home-generated waste disposal is the responsibility of the client, according to state law (see box accompanying this article).
Medical waste refers to pharmaceutical, bio-hazardous (animal tissue), or sharps waste created by the veterinary practice or by a veterinarian in a ranch setting. Disposal of medical waste is usually handled through veterinary distributors or sharps collection and disposal companies. Laws and regulations exist specifically for licensees in relation to the disposal of each type of medical waste. Generally, veterinary practices are considered “small quantity generators” of medical waste, meaning that they produce less than 200 pounds of medical waste per month. For instance, non-controlled drug pharmaceutical waste (such as extra medication or expired drugs) must be deposited into a container labeled “PHARMACEUTICAL WASTE − INCINERATION ONLY.” It may be stored onsite in a sealed container for up to one year if its total weight is less than 10 pounds. More than 10 pounds of pharmaceutical waste must be removed from the practice within 90 days. A practice may also keep a full, sealed sharps container on site for up to 30 days before it is transferred to the proper disposer. Such containers need to be labeled “SHARPS WASTE − BIOHAZARD.” These laws only pertain to veterinary practices. Home-generated sharps rules are different. While the California law changes in 2008 and 2009 implemented home-generated disposal requirements, they did not require veterinarians to take back medications or sharps from clients.
What is the veterinarianʼs obligation in relation to home-generated sharps and pharmaceutical waste? Veterinary practices are not obligated−nor authorized−to take back home-generated pharmaceutical waste or sharps waste, even if they dispensed them originally. In fact, regulations prevent veterinarians from taking back home- generated sharps and pharmaceutical waste without special licensing by the state.
California Veterinarian Compliance Corner
What should a veterinary practice tell a client who needs to dispose of home-generated pharmaceutical or sharps waste? The California Department of Resources Recycling and Recovery (CalRecycle) has created an interactive website in which a visitor may search in their locale to find nearby designated sharps and/or pharmaceutical waste depository sites. The website: http://www.calrecycle. ca.gov/HomeHazWaste/healthcare/collection is easy to use and provides a map along with a list of designated locations on a county-by-county basis. If a client enters his or her county of residence into the search criteria and comes up empty handed, it may be useful to search in neighboring counties.
For more information on home-generated pharmaceutical waste, visit the CVMA website, or www.calrecycle.ca.gov.
Contact Dr. Grant Miller, Director of Regulatory Affairs at the CVMA with questions or comments.
Disposal of Home-Generated Controlled Drug Waste
Veterinary practices should be aware that it is illegal for them to take back controlled substances that they have dispensed. In order for a veterinarian to take back a controlled substance legally, law enforcement must be present to witness and document the return. There are special programs that exist through law enforcement agencies such as the federal Drug Enforcement Agency in which a person can return controlled drugs at a specific location or participate in a mail-back program.
