Your Waste Management and Compliance Partner.
Just like you, we do not want to be fined.
Introducing Birds Eye Lite, an Online tool specifically designed to make waste characterization quick, easy and accurate.
3 Important Requirements
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.
Hazardous waste determination for non-creditable pharmaceuticals (Subpart P 266.502 (c))
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
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.
Most pharmaceuticals are non-regulated, but you are required to make an accurate determination
Frequently Asked Questions
What is this Waste Characterization fee?
The law requires you to identify/characterize all of your wastes to determine if any of it is hazardous or not.
What if I’m sure we don’t have any hazardous waste?
Even if you determine you do not have hazardous waste, you still have to go through the process of determination and maintain records that you have done so.
What can happen if I don’t accurately identify my waste types?
Non-compliance or failure to do so puts you at risk of large fines. If it is determined that you are improperly disposing hazardous waste, you can be fined up to $77k per day per incident.
What if I determine that we do have hazardous waste?
If you determine that any of your waste is hazardous, trilogy can provide you with options, special containers and labels to collect and properly dispose.
Why does Trilogy MedWaste care if I am in compliance or not?
When customers inadvertently co-mingle hazardous waste with biohazardous waste, all of the waste is considered hazardous. Hazardous waste is more expensive to treat. In addition, Hazardous waste may have to be treated at an entirely different facility. Large fines can be Imposed on us if we accept hazardous waste at a facility strictly permitted to treat medical waste only. Regulatory agencies can shut us down if we accept hazardous waste.
What was the impact of customers not profiling their waste?
For starters, it was driving up medical waste disposal costs and also creating public health and environmental risks. There is evidence that it is harmful to aquatic life and can also negatively impact drinking water.
Why do I need this Birds Eye Waste Identification Tool?
Determination is time-consuming and difficult, often the information is confusing, scattered and hard to interpret. The Birds Eye tool makes waste identification quick, easy and accurate. The tool keeps you in total compliance.
Do we have to use and pay for access to the tool?
You can opt-out if you are already properly identifying your waste types and can prove that you do so.
Why are you charging for it?
Considerable expense has been made by trilogy to build a database with hundreds of thousands of records. Each record has to be carefully analyzed. Since new medications are introduced or existing medications change, combined with the laws also changing, we have to dedicate resources to maintain the database. If you opt-out and commit to doing it yourself, you will soon appreciate the value and time savings it delivers.
Is this a long-term commitment?
If you remain opted-in, there is a minimum 12 month term. or the remaining number of months on your current service agreement if less than 12.
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