Managing pharmaceutical waste can be a tall task for any hospital, large or small. Without a comprehensive program in place, mistakes can be made which result in untimely and costly compliance violations. View this presentation to learn about the major pitfalls that can hinder your program’s success. For more information, please visit: https://www.triumvirate.com/healthcare/pharmaceutical-waste-management.

1. 7 Pitfalls of Pharmaceutical Waste
Management Programs
What They Are & How You Can Avoid Them

2. Meet Your Moderator
James Ciccone

3. During This Webinar
✓ All lines will be muted – please communicate via the
questions tab in your webinar panel.
✓ There will be a Q&A session at the end of the
presentation – submit your question(s) anytime
throughout the webinar.
✓ Slide deck and webinar recording will be sent to you
tomorrow.

4. Meet Your Presenters
Josh Chronopoulos Steve Todisco

5. Who are We?
Focused within life sciences, healthcare, education
and industrial markets, Triumvirate Environmental is a
leading provider of enterprise waste management
and EH&S services in North America.
Service Categories Include:
• Waste Management & Disposal
• EHS Consulting Services
• Field Services
• Onsite Support Services
www.triumvirate.com

6. Who Is This For?
Environmental
Health and
Safety
Environmental
Services
Facility
Management

7. Agenda
Our Philosophy
7 Common Pitfalls of Pharmaceutical
Programs
How to Successfully Manage a Sustainable
Rx Waste Program
Q&A

8. SuCCeSS
Sustainable (Su)
Compliance (C)
Cost Effective (Ce)
Safety (S)
Simple (S)

9. Agenda
Our Philosophy
7 Common Pitfalls of Pharmaceutical
Programs
How to Successfully Manage a Sustainable
Rx Waste Program
Q&A

10. • Poor Stakeholder Management
▪Setting up core meetings with the
key stakeholders
▪Gaining buy-in from set
stakeholders
Pitfall #1:
Pre-Rollout Challenges

11. Pitfall #2:
Cutting Corners in the
Informational Phase
• Obtaining the formulary
• Properly characterizing waste streams
and obtaining hidden waste streams
not currently on your formulary
• Federal Exceptions Listing

12. Formulary Characterization
• Obtain an Up-to-Date Formulary
▪ (NDC #, Brand Name, Generic Name, Form) in
Excel
• Characterization
▪ What medications are regulated?
▪ Medication compatibility
o Waste stream creation
▪ Containers
▪ Labeling/signage
• End Waste Disposal requirements
▪ Waste profile

13. • Potential compliance issues
associated with not consistently
reviewing your formulary.
▪Nurse confusion
▪Compatibilities
▪Unaccounted waste codes
▪Improper labeling
The Formulary
Characterization Process

14. Have hazardous medications been added or removed from the
formulary?
Does your formulary still align with your generator status and
program plan? P-Listed Waste?
• How is this being tracked?
Waste Disposal
• Know when the waste profile needs to be updated
The Formulary
Characterization Process

15. • Determining collection method
• Determining training method and go-live
date with nursing, pharmacy and EVS
• Reverse distribution
• Determining Satellite Accumulation
Areas (SAAs)
• Who will be collecting the waste
(vendor or internal staff)?
Pitfall #3:
Not Having the Appropriate
Team Members Involved in
the Operational Phase

16. How Will You
Manage:
Non-Hazardous Waste?
Narcotic Waste?
NIOSH Listed Waste?
Bulk/Trace Chemotherapy Waste?

17. Roles & Responsibilities
Nursing
Pharmacy
EVS/Housekeeping
Must get all departments involved early to gain
insight and buy-in to the process.
TIP!

18. Satellite Accumulation Area
Identification (SAA)

19. • Pharmacy staff training
• Environmental Services staff
training
• Nursing training
Pitfall #4:
Properly Educating
Your Staff

20. Initial Training
Department Specific!
• Based on Responsibilities (Nursing,
Pharmacy, EVS)
Formal or In-Service Trainings
Future New Hire/Orientation Training

21. Ongoing
Training Plan
Use the resources you
have at your disposal!

22. • Remember that until the new
pharmaceutical law is
promulgated we have run into
issues with small quantity
generators and CESQG’s and
their P-Listed Waste
Pitfall #5:
Small Quantity or CESQG
P-Listed Items

23. Generator Status
CESQG/SQGs
• P-Listed Waste-
2.2 Lbs./Month
CESQG*Less than 100 kg/month
• No accumulation limit up to 1,000 kg
SQG*Between 100-1,000 kg/month
• 180-day accumulation limit
LQG* Greater than 1,000 kg/month
• 90-day accumulation limit
• Most stringently regulated
Are You Properly Registered?

24. • Off-Sites typically get forgotten as
they are not high up on the radar
screen
• Make sure to connect with the
main point of contact at each of
your off-site locations in order to
determine what they are
generating as waste, and how
they are currently managing those
waste streams
Pitfall #6:
Incorporating Off-Sites

25. • Optimizing your Rx program
• How is the program operating?
• Understanding the importance
of an annual evaluation of your
Rx Program
• Ongoing Rx SAA inspections
Pitfall #7:
Go-Live Date &
Post-Rollout Activities

26. Agenda
Our Philosophy
7 Common Pitfalls of Pharmaceutical
Programs
How to Successfully Manage a Sustainable
Rx Waste Program
Q&A

27. Optimizing Your
Rx Program
• Assess how the program is operating
• Understand the importance of an annual
evaluation of the program.
• Ongoing SAA Inspections-Compliance
checks
▪ What are the benefits?
• Container Sampling as a method of
evaluation.
• Continued Training
▪ How to utilize your resources for training
purposes

28. How is the Program
Operating?
• Get Overall Collective Feedback:
▪ Surveying
▪ Direct feedback
▪ Inspection data
• What improvements can be made?
• Is the program sustainable?
• Are you staying within your regulated
limits?

29. Understanding the importance of an
annual evaluation of your Rx program.
Your hospital’s formulary could be
in a constant state of change!

30. Ongoing Rx SAA Inspections
How often are these areas
getting inspected for compliance
by trained personnel:
• Weekly?
• Monthly?
• Never?

31. Ongoing Rx SAA
Inspections
Documented Inspections:
• Offers trending compliance data
• Reassures compliance
• Best management
Electronic Inspections:
• Data is easily attainable (possible
training opportunities)

32. Our Key Message
Understanding the importance of reviewing
and re-evaluating your pharmacy program
on an annual basis.

33. Agenda
Our Philosophy
7 Common Pitfalls of Pharmaceutical
Programs
How to Successfully Manage a Sustainable
Rx Waste Program
Q&A

34. Action Plan
Clearly Identify All Roles & Responsibilities
Track Generator Status Consistently
Get End Users Involved
Review Your Program Annually

35. Discussion
Q: How do I effectively train my staff?
Q: Should I be collecting together or separately?
Q: How do I avoid fines/notices of non-compliance?
Q: Is my formulary all I need to be looking at?

36. QUESTIONS?

37. Thank You For Attending!
You will receive:
• A recording of this presentation and copy of
this presentation
• A link to a short survey
• An offer for a Free Pharmacy Program Scope
Josh Chronopoulos
jchronopoulos@triumvirate.com
Steve Todisco
stodisco@triumvirate.com
Call Us!
1-888-834-9697
www.triumvirate.com