Accurate Waste Determination Is The Law

Working hard as the company you trust to guide your facility to properly manage regulated medical and hazardous waste, Trilogy MedWaste has spent the last three years developing a proprietary software designed specifically to help you reach and maintain compliance for three important requirements.

1. Hazardous waste determination and recordkeeping (40 CFR 262.11)

2. Hazardous waste determination for non-creditable pharmaceuticals (Subpart P 266.502 (c))

3. A hazardous material inventory is required by all employers in order to provide information to their employees about hazardous materials to which they may be exposed to in their workplaces as stated in the OSHA Hazard Communication Standard, 29 CFR 1910.1200

Non-compliance in these three areas can lead to significant fines and penalties for generators of regulated waste. Trilogy MedWaste can also be fined if we accept, transport and treat waste that is improperly classified. Just like you, we do not want to be fined.

To break down these requirements in the simplest terms, every facility that generates any category of waste must make an accurate determination as to whether any of their waste is hazardous in order to ensure those wastes are properly managed according to applicable regulations.

For many healthcare facilities, making an accurate determination as to whether certain solid waste and non-creditable pharmaceuticals are not defined as hazardous can be a daunting task. Researching the characteristics of each and every drug in your facility takes a great deal of time - and the information is often scattered, confusing or difficult to find. The challenge of complying with these regulations often leads to mis-management of regulated waste. Mismanaging or over-managing these waste streams is expensive. Trilogy wants to help you save time and money.

As the company you have contracted for accepting, transporting and treating your waste, Trilogy has a responsibility to make sure that our customers are NOT improperly collecting, storing and disposing their hazardous waste. If governing agencies discover that we were inadvertently accepting and co-mingling certain types of waste, we will be held liable. Large fines and penalties can be imposed, including the potential shutdown of our treatment facilities. Ultimately, these fines drive overall costs up and these added costs are passed down to customers. This hurts everyone. Our mission is to help you with the least amount of cost to you possible.

In seconds, the software analyzes the NDC record and provides an easy-to-read summary of that NDC, including information on whether that product is hazardous or non-hazardous, and guidance on proper disposal. This guidance prevents you from mismanaging or over-managing your pharmaceutical waste, since statistically, most drugs are non-hazardous. When you are audited for compliance by the EPA or other regulatory agency, you can confidently demonstrate that your facility is accurately determining the waste profile on each and every NDC and properly managing that waste.

Beginning December 1, 2021, you will have access to the Birds Eye Formulary Manager. The cost for access will be $24 per month.

EPA’s final rule will reduce the risk caused by hazardous waste pharmaceuticals that enter the environment through flushing down the sink or toilet. Specifically, this final rule is projected to prevent the flushing of 1,644 to 2,300 tons of hazardous waste pharmaceuticals annually by banning the drain disposal (flushing, sewering) of hazardous waste pharmaceuticals.

With this final rule, EPA strives to improve compliance at healthcare facilities (including hospitals, clinics, and retail stores with pharmacies) and reverse distributors that generate and manage hazardous waste pharmaceuticals in order to improve environmental protection. Specifically, EPA enhances public health protection by decreasing the risk of diversion of unused hazardous waste prescription pharmaceuticals onto the black market by requiring basic tracking of these pharmaceuticals from healthcare facilities to reverse distributors. Additionally, this final rule creates an environmentally preferable, convenient and practical management system that EPA encourages the healthcare sector to use for all waste pharmaceuticals.