The EPA Clinical and related waste-operational guidance indicates that pharmaceutical waste must be incinerated. This can only happen in healthcare settings if those who are disposing of medicines are provided with a bin that is streamed accordingly.
ANMF (Vic Branch) members are reporting to us that they are not being provided with suitable pharmaceutical waste bins. Instead, they are provided with alternative disposal streams where contents are not incinerated and can end up either as a diversion risk, or in our water ways.
Just one example members have reported involves being provided with sharps bins as an alternative to pharmaceutical waste bins. But as Department of Health advice notes, placing partially used ampoules containing a drug of dependence into a sharps container does not render the drug destroyed. In numerous cases, these drugs of dependence have subsequently been recovered out of the sharps container by others for illicit purposes.
A VicTAG0The Victorian Therapeutics Advisory Group (VicTAG) is an independent, not-for profit association. VicTAG members are hospital pharmacists and medical specialists from Victorian public hospitals. The Management Committee comprises representatives from hospital Drug and Therapeutics Committees. Quality Use of Medicines (QUM) 2022 state survey also revealed that half of the health services that responded didn’t have a system for pharmaceutical waste streams in all areas.
The Environmental Protection Act 2017 imposes a General Environmental Duty on all businesses ‘to reduce risk to human health and the environment’ from pollution or waste. The National Registration and Accreditation Scheme also imposes compliance requirements on health services in regards to the disposal of unused, unwanted or expired medicines. And the under Victorian Drugs, Poisons and Controlled Substances (DPCS) legislation contains requirements for the compliant destruction of scheduled medicines.
Where a service is not providing appropriate pharmaceutical waste bins for staff to use, it is in breach of the Act, the Scheme and the DPCS legislation. These breaches are increasingly frustrating for nurses and midwives who are trying to practice with regulatory compliance but are not resourced to do so.
What have we been doing?
At the request of members, ANMF has been lobbying the Department of Health, HealthShare Victoria (HSV), Safer Care Victoria, VicTAG, the Society of Hospital Pharmacists of Australia and the Environment Protection Authority Victoria. Most recently, the Branch’s environmental health officer, Ros Morgan, spoke on the issue at the International Forum on Quality and Safety in Healthcare.
We continue to meet with the EPA on the matter, and recently have received information that the EPA is conducting audits at 17 services.
We are seeking that all members working in area generating drug waste are to be provided with pharmaceutical waste bins and appropriate education on their use. Additionally, we require that health services which are found to be non-compliant with the regulations are mandated to implement remedial action plans by end of 2024.
What can members do in the meantime?
In 2020, ANMF worked with the Department of Health and VicTAG to develop educational materials and information on pharmaceutical waste disposal. Members can download posters and tables, training presentations and the Victorian Framework for Handling and Disposal of Pharmaceutical Waste. These materials can help when raising the issue with management.