Determining regulatory costs for hazardous waste compliance

A cost analysis is dependent on many factors, including current generator status, waste segregation policies and vendor relationships. The Environmental Protection Agency (EPA) is actively encouraging the management of all pharmaceutical waste as hazardous waste but has not done a specific cost analysis.

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By removing hazardous waste pharmaceuticals from the calculation of generator status, it is likely that those health care facilities that were kicked up to large-quantity generator status because of P-listed waste, such as nicotine and warfarin, may now return to small-quantity generator or even very-small-quantity generator status. This change should result in lower training and administrative costs and possibly lower hazardous waste volumes. 

If the facility is still drain-disposing controlled substances and stocks any of the controlled substances that become a hazardous waste, it will not be operationally feasible to continue drain disposal. This is because of the difficulty in training nurses to identify which controlled substances can be drain-disposed as to which would need to be sequestered for disposal by incineration, as required by the new rule.

For facilities already using a sequestration device, their costs may be reduced, as the devices can be disposed into the nonhazardous pharmaceutical waste containers under the controlled substance exemption once the rule is adopted by their state. It is important to note that the sequestration devices must be incinerated to comply with the new rule and with landfill disposal restrictions. Many vendors will not accept controlled substance waste that is not sequestered due to the risk of diversion.

The EPA’s Office of Resource Conservation and Recovery is responsible only for hazardous waste pharmaceuticals and has therefore used the new rule to provide incentives for health care facilities to manage all pharmaceutical waste as hazardous waste. For example, the requirements to perform a waste categorization and determine hazardous waste codes are waived if all pharmaceutical waste is managed as hazardous waste, although incompatible waste must still be sorted and segregated. 

Likewise, the requirement to keep records of waste determinations for at least three years after the last shipment is waived if all non-creditable nonhazardous waste pharmaceuticals are managed as hazardous waste.

A cost analysis for managing all pharmaceutical waste has not been performed by the EPA, but the following general figures can be used by organizations to estimate the differences based on volumes:

• Resource Conservation and Recovery Act (RCRA) hazardous waste and “bulk” chemotherapy waste: 88 cents to $1.25.
• Dual RCRA hazardous waste and infectious/sharps: $2.40 per pound. 
• Inhalers/aerosols: $1.10 per pound but normally priced in 5-gallon pails at $61 to $195 per 5-gallon pail.
• Nonhazardous pharm waste: 63 cents to 78 cents per pound at hazardous waste vendors; 35 cents to 40 cents per pound at a medical waste incinerator; and 20 cents to 25 cents per pound at a waste-to-energy facility.

These costs do not include containers, service costs, vendor labor and transportation costs, and related additional charges, but provide some guidance regarding the cost-multiples facilities need to consider before making the decision to manage all pharmaceutical waste as hazardous waste.

On the savings side, training efforts are reduced along with the opportunity for hazardous waste pharmaceuticals being disposed into the wrong container.