Description:
I have a consulting business that assists hospital pharmacies in managing the disposal of waste pharmaceutical product. I use a database I created to organize the inventory of drugs into a hierarchy of concern. Items appear in one category of a waste analysis. An item may be both RCRA Toxic and OSHA Toxic. Since RCRA Toxic appears in the hierarchy first, the product is only categorized as RCRA, with the understanding that proper management of the waste product as RCRA would supersede any OSHA requirements. The categories are below.
1. RCRA Acutely Toxic Waste
2. RCRA Hazardous Pharmaceuticals
3. E.P.A. Categories of Concern are Classified Greenhouse Gases,Contaminant Candidates, or Regulated Pesticides
4. OSHA Toxic
5. NIOSH Toxic
6. F.D.A. Categorized Pregnancy Risk
I update this file quarterly based on a purchasing file the director of pharmacy sends to me in spreadsheet format. I also visit hospitals in person and conduct compliance audits and educational meetings with pharmacy staff and clinical personnel.