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Letters to the Editor
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Waste disposal
Doubts regarding safety of standard operating procedure
From Mr N. H. E. Dixon, MRPharmS
I have been writing our standard operating procedure (SOP) for returned
medicines with regard to the new waste regulations and have been using
the guidelines included in the National Pharmacy Association’s “New
directions” manual.
Our SOP recognises that our returned medicines may include sharps, broken
glass, loose and perhaps powdered cytotoxic materials. We are to tip
these materials onto a suitable surface in the middle of a busy dispensary
and then proceed to sort them. The person doing the handling will be
protected by a mask, apron and disposable gloves.
I think I must be absolutely mad to even to contemplate setting up this
procedure. The bin men in our area tip rubbish out of a full bin directly
into the lorry. They are not allowed to touch the contents of the bin
even if it is in sealed bags.
Looking at the health and safety aspect of this procedure I do not see
how I can guarantee absolutely the safety of the person doing the sorting.
There are strong clinical governance issues here and I feel I should
go back to sending all medicines to our waste handlers in containers
as we receive them. Does this mean that I am in breach of my contract?
Does it mean that there are health and safety responsibilities for those
who have instructed us to provide this service? Do our insurers understand
fully what is involved? Do the people at the top who set this contract
up with both our employers and our negotiators have all the “competencies” to
enable them to ask us to proceed?
When we first started accepting waste medicines, volumes were low and
we put them in a bin just as we received them. Over time, the complexity
of the task has increased, no doubt driven by primary care trusts and
waste handlers trying to contain their costs by getting pharmacies to
do some preliminary sorting. By exempting us from the storage requirements,
as detailed in the new European regulations, the Government has given
us a legal framework within which to operate without any regard for our
safety.
Where is the Pharmaceutical Services Negotiating Committee in all this?
Negotiating — or just implementing Government policy?
Noel Dixon
Stanley, Co Durham
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STEPHEN LUTENER, head of regulation at the Pharmaceutical Services
Negotiating Committee, responds:
The PSNC’s new contract book
(published in autumn 2004) sets out the agreed position for the disposal
of unwanted
drugs service and the terms of service require no greater segregation
than into solids, liquids and aerosols.
The Hazardous Waste Regulations 2005 came into force on 16 July, therefore
after the contract, and place an additional burden on pharmacy contractors,
requiring
them to separate hazardous waste from non-hazardous waste where technically
and economically feasible. This requirement, which is based upon a
European Directive,
is in our view neither appropriate for the assortment of medicines returned
to pharmacies, nor is it part of the agreed contractual framework.
The future funding arrangements agreed with the Department of Health include
a provision that significant increase in regulatory burden would be factored
into future funding negotiations.
The PSNC has been in discussions with the Department of Health and the Royal
Pharmaceutical Society and is soon to meet officials from the Department
of the Environment, Food and Rural Affairs and the Environment Agency to
discuss whether
there is any scope for exempting pharmacy from these requirements. The PSNC
has also raised the matter of increased funding, should pharmacy not be exempted
from the need to segregate. Pharmacy contractors will be aware that the PSNC,
Department of Health and the Society have recently secured improvements to
some
waste issues, through a joint approach to the Environment Agency, so we believe
that the Department of Health understands the nature of this burden, and
recognises the difficulty which it is causing contractors.
Unless, and until, pharmacy is exempted from the requirement to segregate
(if technically and economically feasible), pharmacy contractors should separate
hazardous medicines from non-hazardous medicines only if it can be achieved
without risking the health and safety of staff or anyone else using the pharmacy.
If
it is not feasible to separate hazardous from non-hazardous medicines, then
all the medicines need to be consigned as if they are all hazardous if there
is any
possibility that the waste includes hazardous waste. As the “frequently
asked questions” on waste are often updated, I recommend that this
section of the PSNC website is visited regularly. |
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The
Pharmaceutical Journal