HPNA Recommendations for Safe Drug Disposal in the Home Setting Link to full document (pdf file)
Hospice and Palliative Nurses Association is committed to providing “best practice” recommendations to assist our members in the development of a drug disposal policy in accordance with Federal, State, and Local guidelines as well as the Medicare and Medicaid Programs: Hospice Conditions of Participation (COPs). Drugs once dispensed to the patient are the patient’s personal property.
HPNA supports the following recommendations when developing policies and procedures for the safe disposal of drugs and biologicals, in the patient’s home setting. Following these recommendations protects patients/families and communities from harm, prevents the illegal diversion of unused medications and reduces the negative impact on the environment.
Guiding Principles of Safe Drug Disposal:
· Knowledge of Federal, State, and Local guidelines for proper disposal.
· The commitment to environmentally safe or “green practices” in disposal methods.
· Notice of the provider’s written policies and procedures on the safe management and disposal is made available to the patient or patient representative and family (may be placed in a hospice admission packet).
· Attention to safe management that includes drugs that are discontinued, or no longer needed at the time of patient death.
· Identification of who is responsible for the destruction of the medications, such as the family member/caregiver or the nurse, predicated upon State and Local guidelines as well as the provider’s policy. This may be designated as family member/caregiver or required to be a nurse.
· Instructions on the procedure to follow if there is a take-back program in your area or a process for the family/caregiver or patient representative to donate unused drugs as allowed per State or Local regulations.
· Procedures for the documentation and reporting of drugs that the family/caregiver or patient representative refuses to destroy.
Safe Drug Disposal Policy Components: The development of an organizational policy for drug disposal in the home setting should include but not be limited to the following information:
a) Employees: Annual inservice on safe drug disposal for all employed and contracted nurses with emphasis on training regarding tracking, collecting, and disposing of drugs when discontinued or a patient dies, which includes assessing for potential diversion with teaching alternative methods of disposal if indicated.
b) Patients and Families/Caregivers: Assure the patient and/or patient representative and family/caregiver receive education about the safe disposal of drugs in a language and manner that they understand. Education should emphasize the risks surrounding accidental ingestion by other members of the household when drugs are not destroyed and remain in the home.
a) After the patient dies or the drugs are discontinued, and therefore no longer needed, the person(s) identified as responsible for the destruction should collect the drugs and dispose of them as determined by the procedures identified in the policy.
b) Dispose of drugs on site, unless a community take-back or donation program is available. Nurses must never transport drugs.
a) Documentation of the drug disposal should follow state guidelines as well as the procedure identified in the provider policy (a sample form is attached).
b) The specific drug disposal documentation should be stored in the patient’s medical record.
a) Unless there are specific instructions from the manufacturer, drugs should be disposed of per the policy and in such a manner that does not allow the drug to be unintentionally ingested or easily retrieved.
Destruction in the Home Setting During the Course of Care or at the Time of Death
1. The specific drug destruction process should be carried out per State and Local guidelines as well as provider policy.
2. Always assess for the potential for diversion. If suspected, the drugs should be flushed down the toilet. The provider should determine the need to contact the appropriate State or Local authorities.
3. Always assess for the potential for accidental ingestion. If identified, educate and flush the drugs down the toilet.
4. Follow State and Local guidelines for determining whether to remove the drugs from their original containers. Eliminate all Protected Health Information (PHI) including the patient’s name. Permanent black marker may be used or simply scratch out all identifying information.
5. Modify the contents as follows:
a) Solid Drugs: add a small amount of water to pills (take pills out of blister packs) or capsules in order to partially dissolve them into a slurry. Mix the slurry with any of the materials recommended in liquid drugs section below.
b) Liquid Drugs: add enough cat litter, detergent, vinegar, used coffee grounds, charcoal, or non-toxic powder or spice to create a distasteful, pungent mixture in order to discourage consumption, then place in a sealed container (such as a sealable plastic bag or coffee can) and place in trash. Never mix drugs with toxic chemicals or other products that may be harmful to humans if swallowed or digested.
c) Other types of pharmaceutical waste (e.g., ampules, vials, IV bags, patches): Caution should be taken to carefully dispose of controlled substances. All liquid controlled substances should be disposed of by modifying the contents. Other types of pharmaceutical waste should be modified based on State and Local guidelines and the provider policy.
6. When State, Local, and provider policy allows for the disposal of drugs over the phone, documentation should include:
a) Instructions on whether to remove the drugs from the original container(s) and how to modify the drugs.
b) The specific disposal method.
c) The elimination of protected health information.
d) Documentation in the medical record should reflect all drugs to be disposed of, the education, instructions, and the family’s verbal response as to their understanding of the disposal process.
e) If the family/caregiver/patient representative refuses to dispose of the drugs in the home setting, document the drugs that will remain and the reason for their refusal. Determine the need to contact State and Local authorities.
Drug Disposal Resources
1. Office of National Drug Control Policy: Review the guidelines published by Federal government for best practices (www.whitehousedrugpolicy.gov/publications/pdf/prescrip_disposal.pdf).
2. Community Drug Collection and Disposal: Some states and/or counties have organized Local household prescription drug take-back programs where they will collect unused medications for safe destruction, in compliance with Local laws. It is important to note that controlled substances are not included in take-back programs due to DEA regulations and policies. Furthermore, such take-back programs may be utilized by family/caregivers but nurses or other staff members should never remove drugs from the home.
3. U.S. Fish and Wildlife SMARxT DisposalTM program: Video demonstration for Safe Disposal of Medications (http://www.smarxtdisposal.net/).
4. A Remedy for Residential Drug Disposal: Michigan Department of Environmental Quality (www.deq.state.mi.us/documents/deq-ess-cau-rxbrochure.pdf).
5. USGS Scientists Develop New Method to Measure Pharmaceuticals in Water: (toxics.usgs.gov/highlights/pharmaceuticals_method.html).
Medication Waste & Destruction Decision Tree (pdf file)
Drug Waste and Destruction Log (pdf file)