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Block 1 - Law, ethics and practice > Waste & Sustainability > Flashcards

Flashcards in Waste & Sustainability Deck (19)
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• Sustainability links to pharmacy in two ways; the way we use NHS resources and the impact we have on the environment
• Under the NHS “Five Year Forward View” pharmacists are involved in the development of Sustainability and Transformation Plans (STPs) for their area
• Pharmacy can help by reducing medicines waste and ensuring the safe disposal of unused medicines and clinical waste
• Pharmacy can aid the sustainability of the environment by reducing its carbon footprint


How pharmacy can reduce its carbon footprint

• Switch off unnecessary boilers in summer
• Low energy lighting
• Do not overfill refrigerators
• Turn off unused electrical/office equipment
• Insulate the pharmacy
• Use energy efficient appliances
• Recycle
• Encourage staff to travel by bicycle, foot or public transport
• Monitor energy usage by checking data and bills.
• Efficient home deliveries
• Sharing printers
• Emailing
• Renewable energy sources


Examples of saving resources

• Recycled paper
• Avoiding carrier bags / Charging for bags (and using paper bags)
• Electric / Hybrid vehicles for deliveries
• Efficient deliveries
• Reduce packaging
• Recycling
• Medicine Use Reviews
• Review repeat dispensing/repeat ordering systems


Legislation affecting waste

• Environmental Protection Act 1990
• Hazardous Waste Regulations 2005
– The Hazardous Waste (England and Wales)
(Amendment) Regulations 2009
• Water Resources Act 1991
– Special Waste Regulations 1996
– Controlled Waste Regulations 1992
• Food and Environment Protection Act 1985
– Control of Pesticide Regulations 1986
– Wildlife & Countryside Act 1981
– Animal (Cruel Poisons) Act 1962
– Protection of Animals Act 1911


Environmental Protection Act 1990

• A duty of care applies to all those dealing with controlled waste
• Disposal of unwanted medicines by pharmacies
(including any medicines returned by householders)
– They may only pass waste on to an authorised person
– They must provide a written description of waste to enable others to avoid committing an offence

Authorised person – e.g. a waste management company like PHS.


Controlled & special waste

• Controlled Waste Regulations 1992
– Includes household, industrial and commercial waste of any kind whether thought of as polluting or not
• Special Waste Regulations 1996
– Subject to more extensive documentation before removal from premises
– Includes all POMs


Disposal of waste

• Enforcement under Environmental Act 1990
• Responsibility of Waste Regulatory Authorities
• Local Authorities have responsibility for collection and disposal of controlled waste
– Local authorities are water collection and waste disposal authorities


The pharmacy is solely responsible for ensuring
that waste is:

– Correctly segregated
– Appropriately labelled
– Packaged appropriately for transport
– Stored safely away from public access
– Described accurately and fully on accompanying documentation when removed
– Transferred to an authorised person for transport to an authorised waste site

The pharmacy should ensure that:
– It keeps a register of necessary records and returns
– Staff are trained and aware of the waste procedures
– SOPs are in place to deal with unwanted medicines
from households
NB: Pharmacies are exempt from the need to hold environmental permits (conditions apply)

Registers normally kept on the premises and register must be kept for minimum of three years for hazardous waste (nb keep waste transfer notes for a minimum of two years)
Pharmacies are now automatically exempt from the need to hold environmental permits (the successor to waste management licences) where they are temporarily
storing waste for the purpose of transferring the waste elsewhere for disposal.
The conditions that apply include:
• The waste must be stored in secure containers;
• No more than 50 cubic metres of solid waste can be stored;
• The waste cannot be stored for longer than three months;
• The service is not provided as a waste management service (e.g. you do not receive payment for the service); • The waste must not have a flash point of less than 21oC.
NB premises should be registered as a hazardous waste producer if >500kg per 12-months of hazardous waste produced


Waste classified by chemical properties

• Cytotoxic and cytostatic (hazardous clinical waste)
– E.g. toxic, carcinogenic, mutagenic
• Other (non-hazardous clinical waste)
– Still might have hazardous properties and need to be
segregated e.g. flammable, harmful or irritant

NB Can also be sorted by source e.g. human healthcare (from GP surgeries, nursing homes), animal healthcare (vet medicines), municipal fractions (households,
residential care homes)


Consignment notes – hazardous waste

• Cytotoxic and cytostatic medicines are automatically hazardous waste
• A consignment note must be completed to track
movements and ensure safe disposal
• At the end of each quarter, the waste contractor must notify the Environment Agency of hazardous waste consignments, and is required to submit a return to the pharmacy
• Pharmacies should check all records are complete and retain for 3 years. Sections completed by pharmacy, waste carrier and the destination consignee site


Waste transfer note – non-hazardous waste

• For non-hazardous waste, a duty of care transfer note is required
• Where waste is transferred from one party to another a transfer note must be completed, signed and kept by the parties to the transfer
• The pharmacy completes the transfer note

Pharmacy has legal responsibility for describing the waste. If a contractor collects the same waste at regular intervals over a period no longer than 12 months, a season ticket can be used


Hazardous Waste & Special Waste Regulations

• Requires pharmacies do not mix hazardous waste with other categories of hazardous waste with non-hazardous waste
• Place a duty on a pharmacy that receives mixed waste to separate it (if safe and practical to do so)

So must segregate medicines into :
a. Cytotoxic and cytostatic
b. Other medicines
Must also ensure that:
Chemically-incompatible agents are not placed in the same container
NB in some situations, the waste contractor, or NHS England, may ask that the waste
is segregated into aerosols, liquids and solids (including ampoules/vials)



• Leave medicines in blister packs – reduces potential for reactions
• Single use MDS should be disposed of intact unless they contain CDs
• Do not rinse out glass/plastic bottles, vials or ampoules
• Patient returned medicines – if safe, separate CDs from other medicines. Identification of loose tablets not required


Waste returned to pharmacies from surgeries and nursing homes

• Pharmacists may lawfully accept waste from nursing
homes, GP surgeries etc.
• Essential Service 3 of the CPCF states that “pharmacies
are only contractually obliged to accept unwanted medicines from households (including residential homes)”
• If a pharmacy decides that it will accept waste from
nursing homes etc. the pharmacy must check with NHS
England whether this can be included in the arranged
waste disposal service
• Waste from these sites is subject to stringent controls

Waste from GP surgeries and nursing homes is subject to stringent controls:
Hazardous waste medicines and mixed medicines of unknown composition must be consigned from these premises to the pharmacy using a hazardous waste
consignment note;
The pharmacy receiving hazardous waste is a ‘consignee’ and must keep a register, a site inventory, send consignee returns to the producer, and consignee returns to the Environment Agency. Each consignment received is subject to a charge;
Hazardous waste controls apply to all movements of hazardous waste between nondomestic premises, even if they are part of the same company or organisation; and
Non-hazardous medicines must be transferred to the pharmacy under Duty of Care controls, including a waste transfer note.
There may be additional obligations on pharmacies accepting this waste, and as this is not an NHS pharmaceutical services activity, advice should be sought from the Environment Agency.


Controlled drugs

• Follow legislation
– Misuse of Drugs Regulations
– Misuse of Drugs (Safe Custody) Regulations
– Controlled Drugs (Supervision of Management and
Use) Regulations

• Denature controlled drugs (own stock out of date) under exemption from environmental permit or license (T28)
– This exemption must be registered with the Environment Agency
– Denatured CDs then disposed of as waste medicines
• Pharmacies can accept CDs from patients
– May be denatured without a permit

OOD – out-of-date
Store in CD cabinet until denatured
Can accept CDs from care homes providing personal care for safe destruction and onward disposal. Pharmacies in England and Wales are not able to accept waste medicines, including CDs, from care homes which provide nursing care for disposal under the NHS funded unwanted medicines service.
The RPS guidance to Pharmacists is that patient returned schedule 2 CDs should be recorded and their subsequent destruction recorded (in a separate record to the CD register). Patient returned CDs should be denatured in the presence of another member of staff, preferably a pharmacist or pharmacy technician if available. RPS guidance confirms that the destruction of patient returned CDs, whether they require denaturing or not, does not require witnessing by an authorised person.
Date expired pharmacy stock: It is a legal requirement under the 2001 regulations for pharmacy contractors to have stocks of obsolete, expired and unwanted Schedule 1 and 2 CDs destroyed in the presence of an authorised witness. RPS guidance indicates that for Schedule 3 CDs it would be good practice to have another member of staff witness the denaturing.
An amendment to the Misuse of Drugs Regulations 2001 which came into force on the 16th August 2007 allows Accountable Officers to authorise people or groups of
people (the authorised witness) to witness the destruction of controlled drugs to render them irretrievable. Previously the witnessing of destruction of controlled
drugs was undertaken by the police chemist inspection officers, GPhC (formerly Royal Pharmaceutical Society) inspectors, and the Home Office inspectors. The authorised witness is a person who is not involved in the day-to-day handling of controlled drugs who has been appointed by the CDAO to oversee the management and governance of activities related to controlled drugs.
There is no requirement in the 2001 regulations that the disposal of date-expired medicines in Schedules 3, 4 and 5 to be witnessed or recorded But good practice to have a witness.



• May be received via:
– Patients with diabetes and other self-administering
– Needle exchange
– Diagnostic procedures
• Segregated on basis of medical contamination
– Contaminated cytotoxic and cytostatic sharps
– Other medicinally-contaminated sharps
– Non-medically contaminated sharps

For health and safety reasons:
Needles should not normally be removed from syringes
A second action should not be taken to discharge syringes
Essential service 3 ‘Disposal of Unwanted Drugs’ does not impose an obligation on pharmacies to accept sharps (needle and syringe programmes are a locally commissioned service). Before accepting sharps, pharmacy contractors should ensure that there are suitable arrangements for their disposal.


Water Resources Act 1991

• Prohibits people from:
– Causing or knowingly permitting any noxious, poisonous or polluting matter to enter any controlled
inland water
– Old practice of “flushing (medicines) down the toilet”
is no longer lawful


Special considerations

• “Older” pharmaceuticals e.g. arsenicals and mercurial: special waste – must check requirements for disposal on a case by case basis
• Pesticides e.g. cyanide or strychnine
– Products used for control of rats, mice, flies etc.
– If you sell or stock any pesticide consult following for details
• Food and Environment Protection Act 1985
• Control of Pesticide Regulations 1986


Poisons sold for destroying animals

• Some poisons prohibited under the Animal (Cruel Poisons) Act 1962
• Protection of Animals Act 1911 unlawful to
“…procure to be administered a poisonous or injurious agent”
• Wildlife and Countryside Act 1981 prohibits “laying of any poisonous or stupefying substance” unless licensed