Several loud, inflammatory headlines demanded attention these past couple months, warning that “Drugs Contaminate Lake Michigan”, and “Lake Michigan Contaminated With Prescription Drugs”. It’s an alarming notion, absolutely, but within the hazardous materials industry, it can also serve as an important lesson. Just why is it so important to handle regulated medical waste (particularly pharmaceutical waste) properly, and what do we risk when we don’t?
Pharmaceuticals are hazardous materials first, and therapeutic agents second. It’s essential we treat them accordingly. Pharmaceutical wastes can be classified as hazardous waste, medical waste, or non-hazardous waste depending on the chemical, physical, and toxicological properties. Wastes must be properly identified, managed, and disposed of – particularly the hazardous variety. Their storage, transport, and disposal is strictly controlled by federal and state law.
And as expected, there are consequences when we mismanage. The on-goings at Lake Michigan are a fitting example. Scientists have tested effluent from two sewage outfalls for 54 chemicals used in pharmaceuticals. Twenty-seven chemicals were found in the lake, with four found most frequently: an anti-diabetic drug called Metformin, Caffeine, the antibiotic Sulfamethoxazole, and Triclosan, an antibacterial and antifungal compound. All are considered to present either a “medium” or “high” ecological risk.
We might like to believe this sort of thing is a rare occurrence, but research tells us otherwise. In 1999, the United States Geological Survey (USGS) surveyed 139 streams in 30 states for pharmaceuticals, hormones, and other organic contaminants. They found medications in 80% of the streams. Since then, pharmaceuticals have been found just about everywhere: rivers, ponds, lakes, wastewater effluent, treated drinking water, groundwater and sediment.
Septic systems and most wastewater treatment facilities simply are not designed to remove these chemicals. In 2001, the USGS conducted a study at a drinking water facility to determine if 106 contaminants could survive the treatment process. 40 contaminants were detected in one or more samples of stream water, and several prescription and OTC drugs were detected in the finished drinking water. The accumulation of pharmaceuticals and chemicals in waterways leads to grave concerns about continuous, multigenerational exposure to wildlife and terrestrial species. Humans face their own set of risks, with apprehension about fetal exposure (drugs like Diethylstilbestrol), and antibiotic resistance. It’s really no surprise the EPA considers pharmaceuticals to be an “emerging concern”.
But that’s not the end of it. Mismanaging wastes can also lead to RCRA Correction Action and cleanup enforcement. A separate federal law, the Clean Water Act (CWA) exists solely to prohibit the discharge of pollutants in US waters. Any discharge of hazardous substances must be reported to federal, state, and local officials promptly.
Not only are there lofty penalties for violating federal environmental laws (up to $37,500 per day per violation under most statutes), but a company can be required to pay the costs of cleaning up any contamination resulting from a violation. These clean-up costs can be colossal. Just this year, Wal-Mart admitted to violating the Clean Water Act (CWA) by illegally handling and disposing of hazardous materials at its retail stores across the United States. Wal-Mart ultimately pleaded guilty to charges of environmental crimes, including the mishandling of hazardous waste and pesticides in violation of the Resource Conservation and Recovery Act (RCRA) and agreed to pay a total of $110 million to settle the cases.
There’s no denying the incredible seriousness or usefulness of proper hazardous waste disposal and good management practices. The reasons are clear, but where do you start? Do your best to design and implement a pharmaceutical waste management program. This includes things like eliminating drain disposal, avoiding land-filling, and training your staff, as well as confirming your generator status and ensuring you’ve found a qualified, informed vendor. There are some options available specifically to small facilities, like choosing to manage all pharmaceutical waste as RCRA hazardous waste, which is generally the simplest and most economical solution, but only expert analysis can provide you with the best answer as to whether this approach is a viable alternative.
Providing you with relevant information is just one of the ways Medical Waste Experts can help you. We can also advise you on your specific situation, as well as provide assistance with handling your material and making all necessary reports to regulatory agencies. Give us a call today at 877-977-6518.
(This article was originally posted on the Hazardous Waste Experts blog.)