Start Reducing - Steps for Healthcare Facilities

Step 1: Gather Your Team

First, find at least one top manager or director who supports the idea of reducing pharmaceutical waste.  This person can champion the cause when it comes time to change policies and procedures.

Second, put together a committee involving certain key departments, such as Pharmacy, Nursing, Purchasing, Safety, Education, Environmental Services and Risk Management. Consider inviting staff from oncology, cardiac care, the emergency department and/or operating rooms, as these are most likely to benefit from waste reduction strategies. 

Third, consider hiring a consultant or waste vendor experienced in the field of pharmaceutical waste management and its implementation in healthcare facilities, with a proven track record.  

Alternatively, hire an intern in pharmacy or nursing, or other students with relevant backgrounds (in pollution prevention, waste reduction or healthcare) to help with your waste reduction effort.  The EPA Pollution Prevention website provides a list of internship programs which may be able to provide support to your facility.

Step 2: Review Waste Regulations

Many healthcare facilities are still not managing pharmaceutical waste properly. We encourage you to take this opportunity to ensure that your waste practices comply with federal and state hazardous waste regulations and your state’s infectious or medical waste regulations (there are no federal medical waste regulations).

Start by contacting the staff in your facility who manage hazardous waste, so you can work together on this critical and complex issue.

For an explanation of federal regulations, download and read “Managing Pharmaceutical Waste: A 10-Step Blueprint for Healthcare Facilities in the United States” by Eydie Pines and Charlotte Smith. This is an excellent guide for implementing a pharmaceutical waste management program in healthcare facilities. For additional information, see EPA’s Healthcare Environmental Resource Center (HERCenter) and the Drug Enforcement Administration’s Diversion Resources.

EPA’s regulations do not cover many drugs that could harm human health and the environment, so be sure to review the best management practices outlined in Step 3 of the 10-Step Blueprint mentioned above.

For state regulations, contact your state environmental regulatory organization. (To locate it, check the HERCenter list.) For Wisconsin, see the Department of Natural Resources, search for ‘health care waste’ and review information for non-household generators.

Step 3: Identify Your Facility's Priorities

Decide what is most important for your facility at the outset to ensure that your chosen waste reduction strategies will support your facility’s goals. 

Your priorities may include:

  • complying with regulations regarding controlled substances, hazardous waste and infectious waste
  • reducing the amount of toxic waste generated
  • conserving medications that are in short supply
  • reducing costs of pharmaceutical procurement and/or disposal
  • preventing drug diversion

Put them in order from most important on down.  Your most important priorities will drive your waste reduction choices later on.

Step 4: Identify Current Practices

Identify and analyze your facility's current practices for purchasing, dispensing, prescribing, storing and disposing of drugs. Document all costs associated with each medication considered for reduction. This may include acquisition, labor and disposal costs. Also identify the most commonly-wasted drugs and the areas in your facility that are generating pharmaceutical waste (known as "source areas"). 

In order to choose the appropriate waste reduction strategies, you must determine where waste is generated, which pharmaceuticals are wasted, how they are wasted, and how much is wasted. If you are using interns or students for your waste reduction project or team, this is a good place for them to start.

  • If your facility's pharmacy utilizes a reverse distribution service, use those return records to determine how much and what drugs are commonly wasted and why. Especially note those that go outdated.
  • If your facility has automated dispensing machines, use their dispensing and return records to find not only the type of medicines and the amounts, but also the areas of your facility which are generating pharmaceutical waste.
  • If automatic dispensing records are not available, you can:
    • Implement a system for staff to document all wasted pharmaceuticals over a period of time. This method can be time consuming for pharmacy and nursing employees. Another option may be to:
    • Perform a waste audit. With this method, drugs are sorted and documented manually. This option will perhaps provide the most detail, but is time consuming and potentially hazardous for inexperienced assessors.

Getting information from various sources will give you a better idea of your facility's current waste habits and will enable you to make better waste reduction choices.

Step 5: Interview Staff

Conduct interviews or surveys of pharmacy, nursing, and staff in various departments at your facility. Ask about current pharmaceutical waste habits and practices, and for ideas and input. This will tell you more about which drugs are commonly wasted and why, and allows vital staff members to give feedback early on in the process. 

Let each person know who to contact if they have future ideas for reducing pharmaceutical waste.  Your conversation may stimulate their thinking.

Step 6: Prioritize Drugs to Reduce

Decide which drugs or waste source areas to focus on first based on your facility’s waste reduction goals.

Our Evaluation Matrix may be helpful for this task. Either drugs or waste source areas can be rated on a scale from 0 to 10 based on factors such as total volume wasted, drug shortages, acquisition cost, disposal cost, amount wasted, environmental toxicity (see NIOSH), worker safety,  etc.  Assign values for each factor, and total them to get your facility’s “top priority” pharmaceuticals or waste source areas.   For more on the Evaluation Matrix, see Step 8.

Step 7: Identify Possible Strategies

A.  Ask staff who prescribe, prepare, administer or purchase the drug for their suggestions of how this drug might be reduced.  

Search by drug name to review case studies of what others have done to reduce specific drugs. Search by source area for suggestions on which drugs to reduce and what waste reduction strategies to use.

B. See Strategies recommended for general pharmaceutical waste reduction.

Reviewing our lists of waste reduction strategies can give you some ideas about where to begin. For example:

  • If your facility produces a large amount of waste from samples, you might consider implementing a voucher system or trial sizes for initial prescriptions.  
  • If a particular drug often goes unused before disposal, but is available in a smaller size, consider minimizing the purchased container size.
  • If you want to send drugs home with patients, learn how to label them for home use.

Step 8: Choose Waste Reduction Strategy

You have identified your priorities, the drug(s) you want to reduce and some possible strategies.  You may now use our Evaluation Matrix to decide which strategy to try first.  

The Evaluation Matrix consists of three Excel spreadsheets.  The first can help you evaluate strategies by drug, the second by source area and the third by strategy.  Access the three spreadsheets by clicking on the tabs at the bottom of the spreadsheet. 

You are encouraged to customize these spreadsheets, as follows: 

  • Include your facility's priorities and remove columns that are not important to you.
  • "Weight" a given priority by muliplying values in that column by, for example, doubling them.
  • Assign values to each option/priority based on a scale of, for example 1 to 5 or 1 to 10.  Alternatively, rank the options for each priority from 1 to the number of options you are considering.  

The one thing to remember is to have higher values (or ranks) be more favorable or "better" than lower numbers, so that the highest total score will denote the best option.

Step 9: Implement Strategy

First propose the selected reduction strategy to a committee of representatives from all affected parties. This may include Pharmacy, Nursing, Environmental Services, Infection Control and Purchasing. Together, create a plan of action detailing reduction goals, actions required and staff involved.

Second, consider implementing a pilot study to determine:

  • Feasibility of system in the field
  • Effective methods of establishment
  • More accurate cost-saving projections

Third, if policy revisions are required, submit a proposal to management. This will formalize the change in practice and serve as a reference.

Finally, educate everyone who is affected by this strategy. Posters, computer modules and training sessions are just a few methods of doing so.

Step 10: Monitor Your Progress

Document your results by:

  • tracking cost savings in acquisition, labor and/or disposal.
  • asking staff involved about what worked and what did not.
  • auditing waste containers.
  • surveying for patient satisfaction if appropriate

Return to main Pharmaceutical Waste Reduction page.

©2015 Healthcare Environmental Resource Center