Pharmacies_checklist

Supplemental Checklist for: Pharmacies MONTEREY BAY AREA GREEN BUSINESS PROGRAM
Supplemental Checklist: Pharmacies
The following measures are intended to supplement those in the Minimum Measures and Office/Retailchecklist. In addition to completing the Minimum Measures and Office/Retail checklist, this checklistmust also be completed prior to certification. Remember, the program offers free, non-enforcement, technical assistance to help meet the criteria. Wewill send out professional technical staff to assist you in meeting the energy, water, resource conservation,and pollution prevention requirements.  Online applications are now being accepted for businesses located in Santa Cruz, Monterey and San BenitoCounties. Please visit: http://www.montereybaygreenbusiness.org/HowToBecomeGr.html to fill out anapplication.
 For businesses located in the unincorporated areas of Santa Cruz County, Scotts Valley, and Capitola, orWatsonville call (831) 477-3976 or email: greenbusiness@co.santa-cruz.ca.us  For businesses located in Monterey County, call Monterey County Environmental Health at (831) 755-4579 or email: recycle@co.monterey.ca.us  For businesses located in the City of Santa Cruz, call (831) 420-5160 or email: shealy@ci.santa-cruz.ca.us  For businesses located in San Benito County, call (831) 636-4110 or email: sbciwm@iwm.co.san-benito.ca.us Green Business Checklist
Business must be compliant with regulatory requirements as well as all of the criteria outlined below to
obtain Green Business status, except where a choice is given. If a certain section does not apply to your
business, mark it with N/A for Not Applicable. For instance, if there are no company owned vehicles
mark that section N/A.
Pharmacies ChecklistLast Updated September 29, 2010 Supplemental Checklist for: Pharmacies A. Pollution Prevention
(Before GB program)(After GB program)1.
All mercury containing instruments are no longer used. Including:  Patient thermometers.
 Blood pressure monitoring devices.
Substitute PVC-containing products for these PVC-free products  Polyethylene containers/reusable containers for sharps containers.
Reduce the use of products that qualify as universal waste (fluorescent lamps, mercury thermometers, batteries, blood pressure gauges etc.). This will lessen the amount of hazardous universal waste that mustbe disposed of later.
ical Waste; Sharps Biohazardous Wastes: Pathological, Infectious, Pharmaceutical, Sharps, and (Before GB program)(After GB program)1.
All Medical Waste Generators must have required permits.
(Before GB program)(After GB program)1.
When possible, recommend over the counter medications that contain less toxic substitutes(i.e. avoid products like selenium including dandruff shampoo and zinc ointments).
Inform patients/customers of the proper methods of prescription drug disposal when fillingprescriptions (i.e. not down the sewer). Implement a sharps and pharmaceutical waste collection program for used sharps and expiredor unused pharmaceuticals from all patients. An example of such a program is SharpMedSolutions (www.sharpmedsolutions.org). Obtain approval from Environmental Health toimplement a sharps and pharmaceutical waste collection program. Perform annual assessments to review containment and disposal requirements for RCRA-based pharmaceuticals and hazardous wastes.
Green Note: Pharmaceutical Waste Take-Back Programs.
Although approval is needed from County Health Departments to become a consolidation point
for sharps and pharmaceutical waste take-back programs, there is no fee associated with the
approval. Ask your Green Business Program Coordinator or contact your local Healt
F. Employee Awh
areness and Training
Department to see if you are eligible.
Designate at least one employee to be responsible for developing and implementingenvironmental programs.
Pharmacies ChecklistLast Updated September 29, 2010 Supplemental Checklist for: Pharmacies Demonstrate that a waste segregation training program is in place. Improved procedures andincreased education can dramatically reduce the amount and the toxicity of waste beinggenerated.
Review Appendix A and Appendix B (attached to this checklist) with employees at regular intervalsand at least twice per year. Ensure employees understand the definitions of the different classes ofmedical wastes with an emphasis on “infectious wastes.” Local environmental regulators and/ormedical facility regulators may be able to assist you.
Internal environmental audits are conducted regularly by facility staff or consultants.
Personnel in all departments are trained for awareness for their roles in pollution preventionand waste minimization.
Poster, fliers, and signs are used to remind employees of pollution prevention strategies. Forexample, label instruments and processes that use problem substances so the user is aware ofhis/her responsibility.
An employee will be asked if they know what Green Business and/or Best EnvironmentalPractices are. They will be asked to list an example of a Green Business or Best EnvironmentalPractice.
G. Compliance Checks
Business is permitted by or registered with Environmental Health and has not had any SIGNIFICANT health violations that have not been corrected (confirm with Environmental Health Services/ConsumerProtection Agency). All criteria have been met as of the following date:       Signature of authorized Green Business Program Coordinator: Pharmacies ChecklistLast Updated September 29, 2010 Supplemental Checklist for: Pharmacies Compliance Notes
Compliance with environmental regulatory laws is required to be certified as a Green Business. The following are some typical compliance
issues that businesses find challenging:
All expired, unused, or partially filled vials, bottles, bags, and tubing for P-listed drugs under the Resource Conservation and Recovery Act of 1976 AND all empty containers for P-listed waste must be disposed of as hazardous waste.
o
A Hazardous Waste
 P012 - Arsenic trioxide (Trisenox)  P042 - Epinephrine (Adrenalin)***  U035 - Chlorambucil (Leukeran)  P188 - Physostignine salicylate (Antilirium)  P001 - Warfarin >0.3% (Coumadin)  U181 - 5-Nitro-0-Toluidine  U109 - Benzene hexachloride shampoo  NOT include epinephrine salts as part of the
 U206 - Streptozotocin  U237 - Uracil mustard  U248 - Warfarin <0.3% (Coumadin)  * Pharmaceutical Waste must be placed in a container labeled “INCINERATION ONLY”. Both sharps non-sharps approved
pharmaceutical waste containers are available through your medical waste hauler.
Containers with less than 3% of original total volume are considered as either holding trace amounts or empty. These containerscan be placed in the regular trash (please note, this does not apply to RCRA hazardous wastes)  Small amounts of liquid pharmaceutical wastes may be dumped on a special absorbent pad placed inside a pharmaceutical waste container -- the empty syringe may then be disposed of in sharps container or empty vial disposed of in the regular trash. If theneedle is removed (must be placed in a sharps container) from the empty syringe the latter may be discarded in the trash. Contact your Medical Waste Hauler to obtain absorbent pads.
 Dispose of full containers within 90 days, and remove at least once a year.  Certain pharmaceuticals (i.e. expired crash cart meds and unused chemotherapy) meet guidelines for ignitability, corrosivity,
toxicity, or flammability and are hazardous wastes under the Federal Resource Recovery and Conservation Act (RCRA). These
wastes and empty containers MUST be segregated from pharmaceutical waste. Large quantity generators (100 kg or more per
month) must obtain a Federal EPA ID number and have the waste picked up by a Federally approved Hazardous Waste hauler.
Small quantity generators must obtain a Cal EPA ID from the California Department of Toxic Substance Control (DTSC) and
may drop their hazardous waste off at their local Household Hazardous Waste Collection Sites for a fee.
County of Santa Cruz Household Hazardous Waste Drop-off center
http://www.dpw.co.santa-cruz.ca.us/www.santacruzcountyrecycles/PDF/FeeSchedule.pdf#page=5
California Department of Toxic Substance Control:
Pharmacies ChecklistLast Updated September 29, 2010 Supplemental Checklist for: Pharmacies Appendix A
Medical Waste Management Act, Health and Safety Code
Pharmaceutical Waste
 Section 118275 (g) Pharmaceutical Waste must be placed in a container labeled
“INCINERATION ONLY”. Both sharps and non-sharps approved pharmaceutical wastecontainers are available through your medical waste hauler.
 Containers with less than 3% of original total volume are considered as either holding trace amounts or empty. These containers can be placed in the regular trash (please note, this does notapply to RCRA hazardous wastes)  Small amounts of liquid pharmaceutical wastes may be dumped on a special absorbent pad placed inside a pharmaceutical waste container -- the empty syringe may then be disposed of in a sharpscontainer or empty vial disposed of in the regular trash. If the needle is removed (must be placedin a sharps container) from the empty syringe the latter may be discarded in the trash. Contact your Medical Waste Hauler to obtain absorbent pads.
 118280(e) Dispose of full containers within 90 days, and remove at least once a year. Hazardous Wastes (RCRA)
 Certain pharmaceuticals (i.e. expired crash cart meds and unused chemotherapy) meet guidelines for ignitability, corrosivity, toxicity, or flammability and are hazardous wastes under the Federal
Resource Recovery and Conservation Act (RCRA). These wastes and empty containers MUST
be segregated from pharmaceutical waste. Large quantity generators (100 kg or more per month)
must obtain a Federal EPA ID number and have the waste picked up by a Federally approved
Hazardous Waste hauler. Small quantity generators must obtain a Cal EPA ID from the California
Department of Toxic Substance Control (DTSC) and may drop their hazardous waste off at their
local Household Hazardous Waste Collection Sites for a fee.
Useful web links:
County of Santa Cruz Household Hazardous Waste Drop-off center
http://www.dpw.co.santa-cruz.ca.us/www.santacruzcountyrecycles/PDF/FeeSchedule.pdf#page=5
California Department of Toxic Substance Control:
http://dtsc.ca.gov/IDManifest/index.cfm
Pharmacies ChecklistLast Updated September 29, 2010 Supplemental Checklist for: Pharmacies Appendix B – Medical Waste Definitions
CA Health and Safety Code
Section 117700 NOT Medical Waste:
Urine, feces, saliva, sputum, nasal secretions, sweat, tears, or vomitus, unless it contains fluid blood, as provided in subdivision (d) of Section 117635.
Waste which is not biohazardous, such as paper towels, paper products, articles containing non- fluid blood, and other medical solid waste products commonly found in the facilities of medical wastegenerators.
(d) Hazardous waste, radioactive waste, or household waste, including, but not limited to, home-generated sharps waste, as defined in Section 117671 Section 117635 Biohazardous Wastes Defined:
(d)Waste…containing recognizable fluid blood, fluid blood products, containers or equipment containingblood that is fluid, or blood from animals known to be infected with diseases which are highly communicableto humans (e) Waste containing discarded materials contaminated with excretion, exudates, or secretions from humans or animals that are required to be isolated by the infection control staff, the attending physician, andsurgeon…veterinarian, or the local health officer, to protect others from highly communicable diseases….
(2)….chemotherapeutic agent means an agent that kills or prevents the reproduction of (3)…a container, or inner liner, removed from a container, which previously contained a chemotherapeutic agent, is empty if the container or inner liner removed from the container has beenemptied by the generator as much as possible, using methods commonly employed to remove waste ormaterial from containers or liners, so that the following conditions are met: If the material which the container or inner liner held is pourable, no material can be poured or drained from the container or inner liner when held in any orientation, including,but not limited to, when tilted or inverted.
(B) If the material which the container or inner liner held is not pourable, no material or waste remains in the container or inner liner that can feasibly be removed by scraping.
(g) Waste that is hazardous only because it is comprised of pharmaceuticals, as defined in Section 11747.
Notwithstanding subdivision (a) of Section 117690, medical waste includes biohazardous waste thatmeets the conditions of this subdivision. Biohazardous waste that meets the conditions of this subdivisionis not subject to Chapter 6.5 (commencing with Section 25100) of Division 20 Section 117690 - Medical Waste:
(a) “Medical waste” means waste which meets both of the following requirements: The waste is composed of waste which is generated or produced as a result of any of (A) Diagnosis, treatment, or immunization of human beings or animals.
Pharmacies ChecklistLast Updated September 29, 2010 Supplemental Checklist for: Pharmacies (B) Research pertaining to (A) above.
Production or testing of biologicals.
(D) The accumulation of properly contained home-generated sharps waste that is brought by a patient, a member of the patient’s family, or by a person authorized by the enforcementagency, to a point of consolidation approved by the enforcement agency pursuant to Section117904 or authorized pursuant to Section 11847.
Biohazardous Waste.
Sharps Waste.
Section 118275 (g) Pharmaceutical Waste must be placed in a container labeled “INCINERATION
ONLY”. Both sharps non-sharps approved pharmaceutical waste containers are available through your
medical waste hauler.
Pharmacies ChecklistLast Updated September 29, 2010

Source: http://www.montereybaygreenbusiness.org/PDF/checklists-09/Pharmacies_Checklist.pdf