EPA regulations will soon affect optometric practices
Hazardous waste pharmaceutical(HWP) management standards will now prohibit health care facilities from disposing of such wastes down the drain, part of streamlined environmental regulations that affect optometric practices and clinics.
Applicable to all health care facilities, regardless of size or waste generation, in all states beginning Aug. 21, 2019, the Environmental Protection Agency's (EPA's) final rule aims to reduce the environmental and human health risks associated with some 1,644 to 2,300 tons of HWPs annually flushed down sinks, toilets or drains. The rule strives to bolster compliance among health care facilities and reverse distributors not only to improve environmental protection, but also to decrease risk of diversion of unused prescription HWPs onto the black market.
Currently, thousands of over-the-counter and prescription drugs are sold in the U.S., so the EPA notes it's difficult to provide a precise number of pharmaceuticals deemed "hazardous waste." That said, the EPA considers any pharmaceutical waste "hazardous" if it exhibits one of the characteristics described in title 40 of the Code of Federal Regulations Part 261. Additionally, waste pharmaceuticals are deemed hazardous if they're ignitable, corrosive, reactive or toxic.
Therefore, the AOA advises doctors of optometry to no longer rinse the remaining residue from empty pharmaceutical vessels and packaging, instead disposing of HWPs and packaging in hazardous waste accumulation containers. What's more, these new EPA regulations require certain HWPs to be sent to reverse distributors for manufacturer credit and, thus, cannot be disposed on-site.
Based on the AOA's evaluation, these new regulations will not apply to lens-edger waste from spectacle lenses—"swarf"—as that byproduct is not considered a pharmaceutical, per the EPA's definition. Doctors of optometry with optical labs on-site are not required to make changes to swarf disposal based on this rule; however, the AOA will continue to monitor developments in solutions for recycling polycarbonate waste.
Although these changes take effect Aug. 21, the EPA has indicated there will be no new inspection requirements for health care facilities.
- Access FAQs about the EPA's revised HWP management standards.
- Watch the EPA's webinar on revised HWP management standards.
These revised HWP management standards stem from inconsistencies and difficulties applying the industry-oriented Resource Conservation Recovery Act (RCRA) to health care facilities and reverse distributors, the EPA notes. The RCRA—which governs the generation, management, storage, treatment and disposal of hazardous wastes—originally lumped the health care sector amongst general industrial hazardous waste generators, sowing confusion and prompting health care workers to dispose of HWPs as municipal or medical waste.
The EPA hopes these "streamlined and tailored" management standards will be more practical and convenient for the health care sector, and ensure facilities are properly managing all pharmaceutical waste.
If doctors have any further questions, contact AOA staff member Kara Webb.
While we're on the subject...
Contact lenses also require an environmentally friendly disposal process of which many patients may be unaware. Earlier in 2018, an Arizona State University study found as many as 1 in 5 contact lens wearers dispose of their lenses down the sink or toilet, contributing at estimated 6-10 metric tons of plastic lenses to U.S. wastewater each year. Furthermore, those lenses break down into microplastics at treatment plants, posing a risk to marine organisms and food supply, researchers claimed.
To help bolster awareness around proper contact lens disposal, the AOA's Contact Lens and Cornea Section (CLCS) developed a resource to help doctors educate their patients. Here are three tips:
- Inform patients about recycling programs available for contact lenses and packaging, including terracycle.com, or consider turning your practice into a recycling drop-off site.
- Most contact lens packages are stamped No. 5 for recycling. Notify patients to remove the foil packaging and ensure the plastic is clean prior to recycling.
- Remind patients that boxes and cleaning solution bottles may be recyclable, too.
The clarification addresses common questions about how doctors can provide audio-only telehealth without running afoul of HIPAA requirements.