Whether work in a hospital, doctor’s office, nursing home, or other medical-related facility with pharmaceuticals onsite, there are bound to eventually be expired medications that need to be properly dealt with. While there are strict regulations that govern how you can dispose of expired medications, many people in medical facilities are either unaware of those regulations or ignore them. One area of particular confusion relates to shipping medications that have expired to a reverse distributor.
What Medical Facilities Need to Know About Reverse Distributor and Expired Medications
What Is Reverse Distribution?
This involves a person or group that collects unsold, expired, or damaged goods and sells them back to the manufacturer for credit. This reverse distribution process is common with pharmaceuticals and medications.
While it is dependent on the distributor, that person or group could even potentially pay the medical facility something for the expired drugs. On the other hand, they might also charge a small amount for the handling of that service. Whatever fees they pay out or charge, they still get credit from the pharmaceutical manufacturers.
What Can You Send? What Can’t You Send?
You can send your expired medicines for reverse distribution if they are reusable. This means those medicines have not been opened, used, or contaminated in any way. It is permissible to send those items back to the manufacturer for repackaging.
If the medications have been opened, used, or otherwise compromised, those cannot be sent for reverse distribution. They are considered waste at that point and should be handled as such. This entails proper identification, packing, containerizing, manifesting, and shipping. For hazardous medicines, it also means sending them for incineration.
What’s Happening Now?
Although the regulations are in place for proper handling and disposal of expired medications, many hospitals, nursing homes, and other medical facilities are not abiding by those rules. Rather than treating the unusable medicines as waste, they are simply sending all expired pharmaceuticals and medicines to the reverse distributors.
This is in part because the reverse distributors will often take anything. Even though they should only be accepting reusable medications, that is often not how the system works in practice.
Violations of Regulations
Some of the most common violations involve improper permitting. For reverse distributors to legally and properly handle this expired medicine waste, they must have hazardous waste permits.
Also, large shipping companies often transport these hazardous items, but to be in full legal compliance, every company handling that waste at every leg should be fully permitted. This is largely not the case.
Some violations are even as egregious as just dumping waste medicines down the drain, where they can eventually find their way into the water supply.
All these kinds of violations have been perpetrated for many years, but just recently legislators have started to address these issues. Rather than looking to retroactively go back and punish people who have been out of compliance, however, they are simply looking to move forward with better, stricter enforcement.
Potential Changes in the Rules
These rules regulating the selling and shipping of expired medications and who’s at fault for improper handling are not set in stone. There are currently discussions about new regulations determining culpability in the mishandling of expired pharmaceuticals.
The Resource Conservation and Recovery Act (RCRA) of 1976 states that the generator (hospital, manufacturing site, doctor’s office, etc.) is ultimately responsible for all waste material and its proper disposal. The group accepting the expired medicines could conceivably get in trouble, but the majority of the burden currently rests with the generator. After these current discussions conclude, there could potentially be legislative change to amend who’s at fault in these kinds of situations.
If these regulations are ever confusing or unclear, you can always seek out full-service waste management companies to offer guidance.
For more information about the protocol related to expired pharmaceuticals and reverse distribution, please contact a representative of full-service waste management company MCF Environmental Services