Robin Watson, MPH, MS

Pharmacy-based immunizations have become standard over the past 2 decades in the United States, a service that has positively affected every community.

 More than 280,000 pharmacists have been trained to administer vaccines in the United States since 1996, and since 2016, more than 25% of adults have received influenza vaccinations in pharmacies.

As immunization advocates who educate the public on vaccine-preventable diseases and champion all patients remaining healthy, pharmacists also work with other health care providers to facilitate the administration of vaccines. As frontline health care workers often serving their communities as a point of reference for health issues, pharmacists play a fundamental role in health education programs and disease prevention schemes, with the ability to tailor information according to their community and, where necessary, provide special training to their staff.

Immunization administration requires many elements, including vaccine vials, needles, syringes, and adhesive bandages.

 The COVID-19 pandemic has led to increased vigilance over the proper disposal of these materials as well as the necessity of using protective personal equipment (PPE).

 It is important to know the regulations for the proper disposal of items used during immunizations. For example, there must be a safe method to dispose of used needles and syringes, so sharps disposal containers should be present at all times during the immunization process.

 Different requirements for the disposal of empty or partially empty vaccine vials, as well as of PPE, which can be disposed of either as medical waste or in the regular trash depending on certain guidelines, are explained further in this article.

 Safe and compliant disposal is required and regulated by state and federal agencies.

 The regulatory requirements section of this article provides an overview of the relevant training and conditions.

Disposal requirements for empty vaccine vials are dependent upon the state in which the waste is generated. Some states allow disposal via trash, and others require sharps containers. If allowed, unused vials may be returned to the manufacturer, otherwise disposal options depend on the vaccine formulation. Full or partially used vials containing preservatives such as thimerosal (usually found in multidose vials) must be managed as a federally hazardous waste when the concentration of mercury is equal to or greater than 0.2 mg/L.

 Vials containing residual, preservative-free (ie, non-Resource Conservation and Recovery Act regulated [nonhazardous]), live attenuated formulations should be disposed of as biohazardous waste. Disposal of preservative-free non-live attenuated vaccines depends on state requirements.

The safe use and disposal of sharps under the Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens (BBP) Standard,

 as well as individual state rules on medical waste management, applies to immunizers working within the pharmacy and at off-site clinics. These rules require the immediate disposal of sharps waste into sharps disposal containers (see table) that are placed in visible locations and within easy horizontal reach.

 Once sharps disposal containers are filled to the premarked three-quarters line, the lids must be securely fastened prior to removing the container from the workplace.

 Some states require the maintenance of a medical waste management plan, which may require specified storage or labeling or sharps disposal container locations throughout a facility.

Pharmacists who administer vaccinations at off-site immunization clinics where sharps disposal containers may travel between locations must comply with the Materials of Trade regulations of the Department of Transportation (DOT).

 These allow the transport of sharps in disposal containers as a part of doing business without having to register with the state as a medical waste transporter as long as the disposal container is closed, secured against movement during transport, and protected from damage.

 If using a mail-back system for sharps collection, the shipping box can serve as the outer packaging.

 Following proper protocol for sharps waste greatly reduces the risk of accidental needlesticks and facilitates the quick, safe replenishment of containers throughout the vaccination season.

Many pharmacies and pharmacy clinics have incorporated PPE as a standard precautions tool to reduce the risk of disease transmission. The CDC recommends that pharmacy staff who interact with the public, while either immunizing or performing diagnostic tests, should use respirators or medical face masks as opposed to cloth face coverings.

 Such single-use PPE should be carefully removed and properly discarded after use.

 OSHA's BBP Standard requires that items contaminated with blood or other potentially infectious materials be disposed of via a red biohazard bag or container,

 whereas some disposable PPE items, such as gowns, that are not deemed to be contaminated may be disposed of in the regular trash.

OSHA's BBP Standard (29 CFR 1910.1030) was first issued in 1991 to protect employees from occupational hazards posed by exposure to microorganisms present in human blood that can cause disease in humans.

 Employers must assess employee exposure to such contaminants using an exposure determination based on which job classifications entail specific duties and procedures with a reasonable expectation for exposure. They also must identify which waste streams in their workplace pose exposure risks. Depending upon the tasks their staff perform, pharmacies should have documentation of training on BBP and sharps safety, as well as medical waste management plan training if required by their respective state and/or organization.

Compliant management of medical waste is not limited only to OSHA oversight but to other federal entities, including the DOT and Environmental Protection Agency. Health care facilities that have direct pickup of regulated medical waste (ie, sharps disposal containers and used health care materials) must ensure that employees involved in the packaging of that waste also have DOT hazmat training.

As pharmacists continue to administer immunizations and educate their communities, disposal of medical waste continues to be regulated to ensure the safety of these communities. The results of a study published in 2018 found that people see their pharmacist up to 10 times as often as their primary care doctor.

 With the number of pharmacists growing every year and vaccinations remaining among the Health People 2030 goals, communities will keep benefiting from pharmacist-administered immunizations.

is a clinical specialist of regulatory compliance at Sharps Compliance, Inc, in Houston, Texas.

is a senior director of sales at Sharps Compliance.

1. Rosado H, Bates I, Pyzik O, Sousa Pinto G, Besan on L. An overview of current pharmacy impact on immunisation: a global report. International Pharmaceutical Federation. 2016. Accessed May 27, 2021. https://www.fip.org/files/fip/publications/FIP_report_on_Immunisation.pdf

2. Petrelli F, Tiffi F, Scuri S, Nguyen CTT, Grappasonni I. The pharmacist’s role in health information, vaccination and health promotion. Ann Ig. 2019;31(4):309-315. doi:10.7416/ai.2019.2264

3. Supplies you may need at an immunization clinic. Immunization Action Coalition. March 2019. Accessed May 27, 2021. https://www.immunize.org/catg.d/p3046.pdf

4. Shaw G. Navigating PPE waste disposal during a pandemic. Pharmacy Practice News. April 20, 2021. Accessed May 18, 2021. https://www.pharmacypracticenews.com/Policy/Article/04-21/Navigating-PPE-Waste-Disposal-During-a-Pandemic/63065

5. Stop Sticks Campaign: sharps injuries: sharps disposal. CDC. Updated February 26, 2019. Accessed May 3, 2021. https://www.cdc.gov/nora/councils/hcsa/stopsticks/sharpsdisposal.html

6. Sharps disposal containers. FDA. Updated April 28, 2021. Accessed May 25, 2021. https://www.fda.gov/medical-devices/safely-using-sharps-needlesand-syringes-home-work-and-travel/sharps-disposal-containers

7. Vaccine Storage and Handling Toolkit. CDC. March 4, 2021. Accessed May 7, 2021. https://www.cdc.gov/vaccines/hcp/admin/storage/toolkit/storage-handling-toolkit.pdf

8. PharmEcology provides disposal guidelines for the 2016-2017 flu season. PharmEcology. October 11, 2016. Accessed May 7, 2021. https://www.pharmecology.com/News/Details/20

9. Bloodborne pathogens and needlestick prevention. OSHA. Accessed May 27, 2021. www.osha.gov/SLTC/bloodbornepathogens/index.html

10. OSHA fact sheet: OSHA’s bloodborne pathogens standard. OSHA. January 2011. Accessed January 12, 2021. https://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact01.pdf

11. Harris J. How state medical waste regulations differ. Sharps Compliance. April 5, 2017. Accessed May 18, 2021. https://blog.sharpsinc.com/statemedical-waste-regulations-differ

12. Materials of Trade Exceptions. CFR 173.6 (2011). Accessed May 10, 2021. https://www.govinfo.gov/content/pkg/CFR-2011-title49-vol2/xml/CFR-2011-title49-vol2-sec173-6.xml

13. Using personal protective equipment (PPE). CDC. Updated August 19, 2020. Accessed January 12, 2021. https://www.cdc.gov/coronavirus/2019-ncov/hcp/using-ppe.html

14. Interim infection prevention and control recommendations for healthcare personnel during the coronavirus disease 2019 (COVID-19) pandemic. CDC. Updated February 23, 2021. Accessed May 5, 2021. https://www.cdc.gov/coronavirus/2019-ncov/hcp/infection-control-recommendations.html

15. Bloodborne pathogens. OSHA. Accessed May 3, 2021. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030

16. Training requirements in OSHA standards. OSHA. 2015. Accessed May 10, 2021. https://www.osha.gov/sites/default/files/publications/osha2254.pdf

17. Pipeline and Hazardous Materials Safety Administration. Hazmat transportation training requirements. Department of Transportation. October 1, 2016. Accessed April 7, 2021. https://www.phmsa.dot.gov/training/hazmat/hazmat-transportation-training-requirements

18. Tsuyuki RT, Beahm NP, Okada H, Al Hamarneh YN. Pharmacists as accessible primary health care providers: review of the evidence. Can Pharm J (Ott). 2018;151(1):4-5. doi:10.1177/1715163517745517

19. Healthy People 2030. Infectious disease. Department of Health and Human Services. Accessed May 3, 2021. https://health.gov/healthypeople/objectives-and-data/browse-objectives/infectious-disease

Articles

The COVID-19 pandemic has led to increased vigilance over the proper disposal of vaccine-related materials, such as vials, needles, syringes, and bandages.

Where's All This Waste Going? The Environmental Impact of Vaccinations in the Time of COVID-19

The Immunization and Infectious Disease initiative for Healthy People 2020 goal is to “increase immunization rates and reduce preventable infectious diseases."

 While this sounds very concise and achievable, it is a daunting task. However, pharmacists’ ability to administer immunizations in all 50 states brings us closer to achieving the Healthy People 2020 goal. According to Carmen Catizone, DPh, executive director of the National Association of Boards of Pharmacy, “In fact, today, more patients are receiving their vaccinations from pharmacists than other healthcare providers."

Access and affordability of immunizations greatly influence immunization rates. Under the Affordable Care Act, private plans are required to fully cover the cost of recommended vaccinations for adults and children as preventive medical care.

 Medicare, however, only fully covers influenza, pneumonia, and hepatitis B vaccines under Medicare Part B, while other vaccinations are covered under Medicare Part D or Advantage plans.

In their attempt to be proactive about their health and the health of their family members, patients often come to their pharmacist with many questions, including: Which vaccine is best? How much will it cost? Does it cause any reactions? The pharmacist is trying to be as helpful as possible, and the proper procedure to dispose of the waste generated from administering an immunization may get lost in the process. This waste, if disposed of improperly, may pose a risk to the patient, pharmacist, or other employees or shoppers.

Pharmacists have been administering immunizations for years; however, questions still arise regarding certain aspects of proper medical waste management. In this article, we will address the following:

Proper management of expired or recalled vaccines

Necessary labeling and storage of sharps, containers, and transport boxes

Disposal of Vaccine Vials and Expired/Recalled Vaccines

Most pharmacists have been made aware of the requirements for proper disposal of sharps, such as syringes, since they started administering immunizations. The Occupational Safety and Health Administration (OSHA) regulates the handling of sharps, and states regulate their final disposal. OSHA mandates that immunizers use safety syringes, and that these syringes be placed in a compliant sharps container immediately after use. Empty prefilled syringes, even if using safety syringes, must be placed into the sharps container as well.

But what about medication vials or prefilled syringes that are unused? As noted by Leslie Yasinac from the infectious waste program for the State of South Carolina, and by Gina Vallone-Hood, CEHP, environmental administrator, Bureau of Environmental Health, State of Florida, both in written correspondence on December 1, 2015, disposal is determined not only by the contents of contents of the vaccine vial or syringe, but by the state (

In some states, empty medication vials can be placed into the trash. Several states (noted in Table) require that they be placed into sharps containers.

 Always check with your supplier to see which, if any, of the unused vaccine can be returned. If the vials cannot be returned, disposal options must be determined based on the following vaccine delivery method:

 If unused vaccine vials or syringes are expired or subject to recall, it must be determined whether the vaccine exceeds the maximum concentration (0.2 mg/L) for the toxicity characteristic for mercury per federal law. Look for 0.01% thimerosal. These vaccines must be disposed of as hazardous waste if the concentration is >0.2mg/L, or as medical waste destined for incineration if it is <0.2mg/L.

Preservative-free live attenuated vaccines.

Used vials should go into the sharps container. If they are expired or recalled, and remain in their original packaging, they may be sent for incineration with your medical waste disposal company.

Preservative-free non-live attenuated vaccines.

 Your medical waste disposal company may be able to take the expired drugs for incineration. Check with your state as some states may allow these vaccines to be placed into the trash, even though this is not considered a best-management practice.

Having unused vials of vaccine is not the optimal situation, but when disposal of them is necessary, follow the guidance of the manufacturer, the FDA and state regulations, and your organization’s policies. Alternatively, reach out to your medical waste disposal provider regarding the best option.

Storing and Labeling Sharps and Waste Containers

Space for storing sharps and other medical waste containers is limited in the pharmacy. Both OSHA and state health and environmental agencies regulate the storage of containers holding sharps or other medical waste. The pharmacy medical waste management plan, required by many states, must indicate where sharps containers are located within the pharmacy. When not in use, sharps containers should be kept with their lids secured on a shelf or inside a storage cabinet away from unauthorized individuals. States may require that if sharps containers are stored in a cabinet for interim storage, a biohazard label must be placed on the cabinet door.

OSHA requires that when an immunization is being given, a sharps container must be located as close as possible to that point of use.

 Therefore, if you do not have a secured/locked area where immunizations are given and the container can be kept, the sharps container must be carried with the lid secured to the point where the injection is given. Immediately following the injection, the syringe safety component is activated, and the syringe is placed into the sharps container. The lid is then secured and the sharps container is taken back to its permanent storage location.

If a transport or shipping box is used to contain filled sharps containers and is kept in a storage room, states may require that a biohazard label and other state-specific warning signage be placed on the room entrance to let employees know of the presence of a biohazard.

 For example, in California, the room entrance shall be marked with the international biohazard symbol, which must be readily legible from 5 feet.

 Regardless of your state medical waste regulations, it is important to remember that the generator/pharmacy is responsible for employee and customer safety.

As pharmacy-based immunization programs grow and expand to meet the Healthy People 2020 goal, it is imperative that the appropriate handling of sharps, vaccine vials, and sharps containers be researched, documented, and implemented for the safety of all.

JAN HARRIS, MPH, BSDH, is the director of environmental health and safety at Sharps Compliance, Inc, Houston, Texas.

ROBIN WATSON, MPH, MS, is the senior director of sales at Sharps Compliance, Inc, Houston, Texas.

Immunization and infectious diseases. Office of Disease Prevention and Health Promotion website. healthypeople.gov/2020/topics-objectives/topic/immunization-and-infectious-diseases. Updated October 25, 2017. Accessed October 27, 2017.

Carr T. Should you get vaccinated at the pharmacy? 

 website. consumerreports.org/vaccines/vaccinations-at-the-pharmacy. Published April 29, 2017. Accessed October 18, 2017.

Preventive health services. Healthcare.gov website. healthcare.gov/coverage/preventive-care-benefits/. Accessed October 27, 2017.

Medicare coverage of vaccines and immunizations. Medicare Interactive website. medicareinteractive.org/get-answers/medicare-covered-services/preventive-care-services/medicare-coverage-of-vaccines-and-immunizations. Accessed October 15, 2017.

Enforcement procedures for the occupational exposure to bloodborne pathogens. Occupational Safety and Health Administration (OSHA) website. osha.gov/pls/oshaweb/owadisp.show_document?p_table=directives&p_id=2570. Published November 27, 2001. Accessed October 18, 2017.

State regulatory map—medical waste. Sharps Compliance website. sharpsinc.com/regulatory-compliance. Accessed October 18, 2017.

Hazardous waste characteristics. United States Environmental Protection Agency website. epa.gov/sites/production/files/2016-01/documents/hw-char.pdf. Published October 2009. Accessed October 18, 2017.

Regulations governing solid waste. State of Delaware website. regulations.delaware.gov/AdminCode/title7/1000/1300/1301.shtml#TopOfPage. Accessed October 18, 2017.

Environmental protection. Illinois Pollution Control Board website. ipcb.state.il.us/documents/dsweb/Get/Document-12277. Accessed October 18, 2017.

Minimum requirements for the management of medical or biological waste. Massachusetts government website. mass.gov/courts/docs/lawlib/104-105cmr/105cmr480.pdf. Accessed October 18, 2017.

Managing vaccine: how to keep vaccines viable and patients protected. Minnesota Department of Health website. health.state.mn.us/divs/idepc/immunize/hcp/provguide/mangvax.pdf. Published July 2011. Accessed October 18, 2017.

Infectious waste management. State of Oregon website. arcweb.sos.state.or.us/pages/rules/oars_300/oar_333/333_056.html. Updated August 15, 2017. Accessed October 18, 2017.

Forum questions and answers. West Virginia Department of Health and Human Resources website. wvdhhr.org/wvimw/forum.htm. Accessed October 18, 2017.

Solid waste regulations. New Jersey Department of Environmental Protection website. nj.gov/dep/dshw/resource/26sch03a.pdf. Accessed October 18, 2017.

Recall procedures. FDA website. fda.gov/downloads/iceci/compliancemanuals/regulatoryproceduresmanual/ucm074312.pdf. Published October 2013. Accessed September 19, 2017.

Bloodborne pathogens. OSHA website. osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10051. Accessed October 18, 2017.

California Health and Safety Code. §§117600-118360 (2017).

The Immunization and Infectious Disease initiative for Healthy People 2020 goal is to “increase immunization rates and reduce preventable infectious diseases.”

Vaccine Vial Disposal Guidelines

The CDC published the startling fact that “

 in the workplace costs US businesses approximately $10.4 billion each season.”

 Employers consistently look for programs to mitigate the impact influenza has on productivity in the workplace. Innovative pharmacists have taken 

, including the influenza vaccine, to off-site clinics located at employer sites, churches, malls, and various other community locations, with the intent to keep people healthy during the annual flu season, rather than having them experience extended illnesses and loss of productivity.

Not only is it important to follow state and federal regulations regarding vaccine administration, once a pharmacist has completed an off-site clinic, there are often questions regarding regulations surrounding the transport of full sharps containers. These regulations are as important as other considerations, such as insurance and billing, and include those from the Occupational Safety and Health Administration (OSHA), individual states, and the Department of Transportation (DOT).

COMPLYING WITH OSHA AND STATE REGULATIONS 

Immunizers must comply with OSHA’s Bloodborne Pathogens Standard, as well as individual state rules on medical waste management,

 whether inside the pharmacy or at an off-site clinic. Pharmacists should be clear on sharps safety, the use of safety syringes, and disposal of syringes immediately after injection. In addition, there are a few disposal considerations that are important for immunizing pharmacists to remember:

Always bring a sharps container and place it within arm’s reach and peripheral vision of the immunizer.

After the injection, activate the safety device and immediately place the syringe into the sharps container.

Secure the lid on the sharps container before transporting it within the facility, to the pharmacist’s vehicle, and during the drive back to the pharmacy.

Have a small trash bag to contain materials generated during the clinic, such as alcohol swabs, Band-Aids, syringe packaging and caps, and vaccine vials.

Most states allow trash disposal of vaccine vials, unless they contain residual live vaccine, in which case, they must be disposed of in a sharps container.

Empty multidose vials can be placed in the trash. An unused or partial vial would be considered a hazardous waste pharmaceutical and must be disposed of as such.

Some states require all glass vials to be disposed of in sharps containers.

Pharmacists transporting full, or partially full, sharps containers between the pharmacy and the site of the vaccination clinic must comply with the DOT Materials of Trade (MOT) Exception

, which applies to all states. The MOT Exception allows pharmacists to transport sharps in a sharps container, as a part of doing business, without having to register with the state as a medical waste transporter. There are requirements that must be followed:

The sharps container must be securely closed and placed within packaging that is strong, tight, securely closed, and secured against movement during transport.

Nonsharps regulated medical waste must be placed in a single or combination package.

If using a mailback system for sharps collection, the shipping box can serve as the outer packaging. Carrying the sharps container inside the shipping box when traveling will assure compliance.

If immunizing at an off-site clinic in California, a log must be maintained with the sharps container packaging per California Health and Safety Code, Section 11796, Chapter 4(a).

 According to an e-mail from Alison Dabney from the California Department of Public Health, if using a mailback disposal system, a completed tracking form will suffice for the log.

The pharmacist or sponsor of the off-site clinic must e-mail the local enforcement agency at least 72 hours before the event.

Prior to participating in an off-site clinic, the pharmacist should have documentation of his/her annual bloodborne pathogens and sharps safety training

; medical waste management plan training, if required by the state

; DOT hazmat training as prescribed in 49 CFR Part 172, Subpart H6; and training on any applicable organization policies and procedures. For more information on the federal and state trainings needed for specific waste disposal programs, pharmacies can contact their medical waste disposal companies.

In addition to pharmacists providing immunizations inside of pharmacies, their participation in off-site clinics provides a valuable and convenient service to communities and employers. Complying with state and federal regulations that govern the transportation of full sharps containers generated at these clinics is a public safety and risk management responsibility.

1. Make it your business to fight the flu. CDC website. cdc.gov/flu/pdf/business/ toolkit_seasonal_flu_for_businesses_and_employers.pdf. Accessed June 20, 2017.

2. Bloodborne pathogens and needlestick prevention. Federal Occupational Safety and Health Administration website. osha.gov/SLTC/bloodbornepathogens/index. html. Accessed June 20, 2017.

3. State regulatory map—medical waste. Sharps Compliance website. sharpsinc. com/regulatory-compliance. Accessed June 20, 2017.

4. Materials of trade exceptions, 49 CFR § 173.6 (2016). Government Printing Office website. gpo.gov/fdsys/pkg/CFR-2016-title49-vol2/xml/CFR-2016-title49- vol2-sec173-6.xml. Accessed June 20, 2017.

5. Medical Waste Management Act. California Department of Public Health website. archive.cdph.ca.gov/certlic/medicalwaste/Documents/MedicalWaste/2013/ MedicalWasteManagementAct.pdf. Accessed June 20, 2017.

6. Hazardous materials transportation training requirements. U.S. Department of Transportation website. phmsa.dot.gov/staticfiles/PHMSA/Hazmat/digipak/pdfs/ presentation/Training_Requirements(04_07).pdf. Accessed July 18, 2017.

Jan Harris, MPH, BSDH, is the director of environmental health and safety at Sharps Compliance, Inc.

Robin Watson, MPH, MS, is the director of client services at Sharps Compliance, Inc.

Wanda Lingner, RN, BSN, is a clinical specialist of strategic regulatory customer compliance at Sharps Compliance, Inc.

Innovative pharmacists have taken immunizations, including the influenza vaccine, to off-site clinics located at employer sites, churches, malls, and various other community locations, with the intent to keep people healthy during the annual flu season rather than having them experience extended illnesses and loss of productivity.

Sharps Disposal: Assuring Regulatory Compliance During Off-Site Vaccination Clinics

A day does not go by without pharmacists, like most Americans, hearing about the overwhelming prescription opioid epidemic. In the past, when patients or visitors asked hospital personnel how to dispose of their unused or expired drugs, the answer included flushing them or mixing them with coffee grounds and throwing them out. However, due to the passage of the Secure and Responsible Drug Disposal Act of 2010,

 implemented by the DEA’s Final Rule on Disposal of Controlled Substances released on September 9, 2014,

 there now are solutions that provide a safe way to prevent opioid diversion and are better for the environment.

Hospitals with onsite pharmacies are one of several types of health care institutions authorized by the DEA to collect controlled and noncontrolled drugs from consumers through onsite kiosks. However, due to the need to comply with the regulations, plan the logistics, and market the program to the community, hospitals have asked questions such as, “How do we comply with the DEA?” “Where does a hospital get a kiosk?” “How does it get emptied?” “How are the collected drugs transported and destroyed?”

The information below can assist with answering these and other questions, as well as outline the steps to implementing a drug collection program:

The hospital must have an onsite pharmacy and modify its DEA registration to become an authorized collector, for which there is no fee.

The hospital must select a DEA-registered reverse distributor that can provide the kiosk, inner liners for the drugs, transportation, schedule II storage, destruction, and documentation. Like medical waste disposal companies, the vendor is strictly regulated.

 The kiosk and inside container (or inner liner) must meet criteria defined by the DEA.

The vendor must supply a Department of Transportation special permit to transport the material.

The kiosk must have a locking door through which the drugs are dropped. It is recommended that the door providing access to remove the inner liner has 2 separately keyed safety locks. The goal is to add as much security as possible to prevent diversion.

Signage on the receptacle will also help guide users as to which materials can and cannot be deposited into the kiosk, including “no sharps disposal.”

The hospital must provide the vendor with a copy of their “Registrant-Collector” certificate.

The hospital must secure the kiosk in a public area in view of hospital personnel, but not near the emergency department.

When full, 2 authorized hospital employees open the kiosk, close the inner liner, and either store the container in a locked area or send it through a common carrier (eg, UPS) or authorized reverse distributor, as indicated by the vendor.

Each step of placement, removal, storage, and transfer must be documented in a specific manner to comply with the DEA. The reverse distributor vendor can supply the proper forms.

The DEA’s Drug Disposal website is a comprehensive resource, providing easy access to register as a collector, FAQs, industry-specific factsheets, and a “wastage” letter clarifying the disposal of pharmaceutical wastage.

 The final rule does not change the way inventory controlled substances or drug wastage are accounted for and disposed; however, the DEA letter4 clarifies that practitioners shall continue to record the destruction of medication wastage in accordance with 21 CFR§1304.22(c). The letter emphasizes the following:

A controlled substance that has been ordered and dispensed to a patient, but not fully administered, is considered wastage, not inventory, and should be disposed of per 21 CFR §1304.22(c), as well as all applicable federal, state, tribal, and local laws and regulations. No DEA Form 41 is required.

In addition to inventory drugs, drug wastage may not be placed in a disposal kiosk.

Hospital pharmacists play a major role in educating hospital personnel, patients, and visitors on safe management of pharmaceuticals. Hospitals that provide a proper and compliant pharmaceutical collection and destruction program participate in the prevention of drug misuse, which has the potential to reduce hospital visits and deaths in the communities that they serve. 

Jan Harris, MPH, BSDH, is director, Environmental, Health and Safety at Sharps Compliance, Inc.

Robin Watson, MPH, MS, is director of Client Services at Sharps Compliance, Inc.

Wanda Lingner, RN, BSN, is clinical specialist — Strategic Regulatory Customer Compliance at Sharps Compliance, Inc.

One Hundred Eleventh Congress of the United States of America; S. 3397 [act]. DEA Diversion Control Division website. 

www.deadiversion.usdoj.gov/drug_disposal/non_registrant/s_3397.pdf

. Published September 9, 2014. Accessed June 23, 2017.

21 CFR Parts 1300, 1301, 1304, et al. Disposal of controlled substances; final rule. DEA Diversion Control Division website. 

www.deadiversion.usdoj.gov/fed_regs/rules/2014/2014-20926.pdf

Rannazzisi JT. Dear practitioner letter. 

www.deadiversion.usdoj.gov/drug_disposal/dear_practitioner_pharm_waste_101714.pdf

. Published October 17, 2014. Accessed June 23, 2017.

A day does not go by without pharmacists, like most Americans, hearing about the overwhelming prescription opioid epidemic.