The Minnesota Pollution Control Agency (MPCA), along with the seven metropolitan counties, will begin enforcing compliance with long-standing hazardous waste requirements in nursing facilities and home health care agencies effective October 1, 2010.  There have previously been a small number of hazardous waste investigations completed in long-term care, but they were primarily complaint-based inspections (with less than desirable outcomes).  In December 2009 the MPCA notified long-term care providers that effective October 2010, they would begin enforcing all hazardous waste requirements within our industry.

Hopefully organizations are well along the path for compliance with these complex requirements.  There is no simple way to come into compliance with these extensive and confusing requirements.  The best summary is the MPCA’s document titled:  “MPCA Basic Hazard Waste Requirements for Businesses,” which lists 10 Steps to Compliance.  Other helpful resources for compliance may be found on the Regulatory Resources section of the Care Providers of Minnesota website, under the Hazardous Waste Compliance heading.

If you need to determine the lethality characteristics of your pharmaceutical waste, Care Providers of Minnesota has made it a bit easier for you!  Care Providers of Minnesota has petitioned the MPCA, on behalf of all of our members, to permit our members to use the alternate (and easier/cheaper) method for determining lethality of pharmaceutical waste.  Using the alternate method, providers can determine if any pharmaceutical waste falls into any of the six risk criteria groups identified by the MPCA.

Pharmaceutical waste appears to be the most difficult type of waste for providers to determine if they are in compliance with the requirements.  Providers who care for 7 or more individuals, and store medications in a central area for the individuals, will need to (in very general terms) do the following to be in compliance:

• Determine if the organization is going to separate out hazardous pharmaceutical waste from non-hazardous pharmaceutical waste.

• If hazardous pharmaceutical waste is separated out, such hazardous waste must be identified and stored separately and appropriately (with proper labeling and storage limit requirements).  Hazardous pharmaceutical waste must then be transported by an authorized transporter for appropriate incineration, with a signed manifest document provided back to the “generator” to complete the proper disposal documentation.

• Controlled substances must also be separated out for storage to be properly sewered/flushed (with proper documentation internally and to the Board of Pharmacy).  Sewering is still the DEA recommended disposal method for controlled substances.  Providers should notify their local POTW (publicly owned treatment works) water plant of the types and quantities of controlled substances they anticipate sewering.

• Non-controlled and non-hazardous pharmaceutical waste must be properly disposed of (taken away by a contracted entity, sewered/flushed – not recommended), or properly made unusable and landfilled.

• Organizations that generate hazardous pharmaceutical waste will need both a Waste ID # and the appropriate Hazardous Waste Generator License.

Facilities should, of course, also work on reducing the amount of hazardous waste generated at the location . . . the less disposed means lower expenses for proper disposal.

PCA staff has been very helpful in answering provider compliance questions; two staff that have been particularly helpful have been Brandon Finke (651-757-2358) and Hanna Pierce (651-757-2651).  You are encouraged to give Brandon or Hanna a call if you have questions about compliance with hazardous waste requirements.

Doug Beardsley
952.851.2489
dbeardsl@careproviders.org

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