I think clear instructions for the hospitals is necessary. I'd like to see only
hazardous labeling required on storage bins in the pharmacy, and any
return/waste bins. We trialed this process and some staff thought that every dose
should be labeled with a sticker for Hazardous Waste/Dispose of Properly
stickers
and it was incredibly labor intensive and questionably valuable. If the dose is
administered by the nurse, there is no waste to worry about, even residual in a
syringe. Returns to the pharmacy are handled appropriately and put back into
circulation and use as able. True waste could then be dispose of with any
Universal Waste, appropriately labeled as such, and appropriately handled by
Environmental Services of the hospital.
In addition, consulting companies and reverse distributers will try to capitalize on
these regulations for profit-making, and if we do not make the regulations very
clear, it will continue to raise the costs of doing business in health care.
Anonymous public comment
This is comment on Proposed Rule
Amendment to the Universal Waste Rule: Addition of Pharmaceuticals
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