*More* Serious Offenses


Following up on my previous post about Joint Commission micromanagement, we got word of another big “no-no” according to JCAHO’s rules.

We have now been informed that according to Joint Commission rules, in association with EPA studies, there is entirely too much drug contamination in the nation’s water supplies. Therefore, hospitals must now separate waste into multiple bins and dispose of such waste appropriately in order to avoid being fined by the EPA and sanctioned by JCAHO. And JCAHO will go through the garbage during its inspections to make sure that you are complying with the rules, too!

Regular waste goes into a blue bag. Blue bags comprise most of the waste in the hospital.

“Hazardous waste,” must be put it into a black hazard bag. Hazardous medications include epinephrine, phenylephrine (i.e. Neo-synephrine nasal spray), insulin, silvadene, nitroglycerin, prednisone, and silver nitrate sticks and others. Next time you go to the store to buy any of these products, make sure that you wear special gloves and gown. Then when you’re done purchasing them, make sure you read how hazardous they are in the product handouts and how you can only dispose of them in a black hazard bag that you must now purchase from JCAHO-licensed distributors. Oh. Sorry. These drugs are only treated as hazardous inside of hospitals. Carry on.

“Infectious waste” must go into a red bag. Infectious waste includes anything that comes into contact with bodily fluids. All you mommies who throw your kids diapers in the “regular” garbage and anyone who throws used facial tissues in the “regular” garbage is breaking JCAHO laws. Stop it now or you’ll be fined and may possibly be decredentialed.

“Dual pharmaceutical waste” means that waste is both infectious and hazardous. That must go into a purple hazard box immediately. If anything in the “hazardous waste” category comes into contact with any bodily fluid, then it fits this category.  If you spray Neo-Synephrine up your nose and then blow your nose into a tissue, find a purple box immediately. The tissue may spontaneously combust.

“Non-compatible waste” must be placed in a special black bag with an orange triangle. We must then contact the pharmacy for a special waste pick up. Non compatible waste includes any asthma inhalers – due to the propellants contained in the container. In other news, the US Government is currently developing a secret group of mercenaries that will take a couple of puffs off of an asthma inhaler, spray Neo-Synephrine up their noses, cough and blow their noses into a tissue, and then throw the tissues at selected targets. Biologic warfare at its finest. Watch out Al-Qaeda. We mean business.

Controlled substances must be flushed down a toilet while another person watches and then must documented on a special sheet by the toilet. Apparently the risk of polluting our waterways pales in comparison to the threat of someone getting ahold of a couple of drops of extra morphine lying around in a syringe.

Oh yeah, and sharps have to be put in the red sharps container. BUT … if there is medication in the syringe, it must be squirted into a gauze pad and then deposited into the appropriate bin (or flushed down the toilet) as described above before the syringe is discarded.

I keep getting confused about what to do if someone pees on an asthma inhaler or what to do if a kid spits out Tylenol with codeine elixir and hits his mother’s purse.

Sitting dejectedly underneath the doctor’s desk is the lonely metal trash can with its non-JCAHO-approved clear plastic liner.

The whole colored trash can idea reminds me of my childhood.

We-he-he-he-lllll boys and girls. I’ve got a special game for you today. Here’s a pen that looks like a syringe, an asthma inhaler that was dropped in the hospital waiting room, a tissue with an unknown yellow substance on it, a shoelace, and a piece of gum chewed by someone who just immigrated to this country from Congo. Let’s play MEDICAL Bozo BUCKETS!

Stay tuned after the commercial so you can watch JCAHO teach doctors how to run their hospital medical staff.



  1. That sounds like a huge pain in the ass.

    So, do you disagree that medications in the water supply is a problem? Or, do you disagree that many of these meds are coming from hospitals? Or, where exactly do you disagree with the regulations? Because personally I’d rather not be drinking dangerous meds in my tap water. I’m not sure what the right answer is but we definitely should be changing something.

    • Of course I agree that medications in the water supply is a problem — that should be monitored and addressed if those levels become excessive. By the way, water out of your kitchen spigot isn’t exactly sterile to begin with, you know. Is there something about water treatment centers that can filter out sewage but that somehow misses vicodin pills? Used band-aids in the hospital are a deadly threat, but the same used band-aid in the house — eh, no problem.

      I also think that air pollution from automobiles is a problem. I personally would rather not be having my kids breathing dangerous chemicals in the air.
      Therefore, I propose that all red cars should drive only on north/south streets and all trucks should only drive between the hours of 7:13 PM and 1:30 AM. Oh, and foreign imports no longer have to stop at stop lights.
      If you’re asking yourself what these actions have to do with making the air cleaner, you have now understood my point.

      What does segregating garbage have to do with water supply? And if unsegregated garbage is such a threat to the safety of our nation’s waterways, why doesn’t JCAHO create a national health bulletin to force mommies to stop throwing used tissues and dirty diapers in the “regular” garbage?

      Could it be perhaps that the whole organization would be ridiculed out of existence if someone actually stepped back and asked “why the hell are we doing this”?

      • “Used band-aids in the hospital are a deadly threat, but the same used band-aid in the house — eh, no problem.”

        Actually I get annoyed when there are used bandaids lying around my house too. Stupid flatmate, trying to give me his diseases* >_<

        I would love if regular households had a separate bin for hazardous materials, biological weaponry etc. But we have enough trouble trying to get everyone to wrap broken glass before putting it in the rubbish!

        *NB: I have no idea if my flatmate has any communicable diseases.

    • The overwhelming majority of pharmaceuticals that end up in our water supply have passed through (and passed by) patients.

      So I guess we need five gallon jugs, too.

      I have no idea what color they should be.

  2. Will there be special garbage trucks for this dangerous stuff? When will we get a purple trash receptacle for home use? Will I run out of wall space alongside my house? I already have three… Regular garbage, recyclables, and yard clippings.

  3. Is there going to be a pop-quiz on this tomorrow? Talk about anal-retentive… Okay, the answer is not to generate any trash OR make the visitors take the patient’s trash home with them.

  4. Bwahahaha. I know, not funny, really…but it is just another example of assanine rules added to the mix.
    In NC, the regs differ between the “state” and what OSHA defines as something that needs to be disposed of in the red biohazard bags. It’s crazy.

  5. C’mon WC. I’m an engineer working at a medical products design/manufacturing company and we have to go through the exact same stuff. Absolutely no chemicals down the sink whatsoever (every sink and toliet has a warning over it). We have various sealed 50 gallon drums scattered throughout the complex that are specifically meant for various kinds of hazardous waste (HCl, isopropyl,solid, liquid etc). We also have separate “sharps” bins for used razor blades and the like. On top of paying for all this hazardous waste pickup, we also have bins meant for disposing of used batteries (and recycling of those isn’t free of charge either).

    I agree with what we’re doing because it sets an example that it’s not rocket science to deal with. Is it really making a humongous difference for water quality? Probably not, but that doesn’t mean we should just not do it.

    You seem to keep falling back on the bad argument of “if we don’t regulate everything (like automobiles as you cite) then we should regulate nothing”. As to your comment on “why should we care about segregating garbage”…think about it. Garbage-> Landfill -> Rain -> Groundwater.

    • Garbage -> Landfill -> Rain -> Groundwater?

      No. Garbage -> Landfill -> Rain -> nowhere, because there’s a waterproof barrier lining the pit. As another commenter remarked, drugs in the water have largely been preprocessed by patients. Also, “drugs in the water” means squat. What’s the concentration, and how much of that water do you consume per day?

    • Little bit of a difference between drums of hydrochloric acid and asthma inhalers, wouldn’t you say? Show me where I can pick up a bottle of hydrochloric acid in the pharmacy and I might change my mind.
      Asthma inhalers need special disposal when on hospital property, but can be tossed in the regular garbage when off hospital property? Either they’re a threat to human existence or they’re not. Why does location on hospital property make any difference in disposal technique. What if I run out of the inhaler while I’m walking onto hospital property? Do I dispose of half of the inhaler in the regular garbage and half in the super secret disposal bag?
      We dispose of needles the same way regardless of location. Diabetics are supposed to put needles in proper containers. Why are bottles of nasal decongestant any different?

  6. I once worked for a pharmaceutical manufacturer and one of the datacenters was located in a building that also contained labs.

    The refrigerators in the break room had large signs on the front that read “FOOD ONLY – NO CHEMICALS”.

    • Shalom (R.Ph.) on

      The stupidest sentence I’ve ever read was in an article about arrests of suspected terrorists in Australia:

      “*Substances believed to be chemicals* had been seized in Sydney by officers wearing protective clothing, police said.”

      That basically translates to “Stuff that they think is stuff”.

  7. WTF!?! This is getting crazy. WHEN are we/the hospitals going to revolt and tell JCHAO to suck it? If we all drop out they will go out of business. There is no law that hospitals have to be JCHAO approved. This is a waste of time and money. REVOLUTION!

    -ER Doc

  8. I’m pretty sure that machine shops would prefer to just throw the 1,1,1-TCE down the drain. After all, there aren’t THAT many machine shops and they don’t use THAT much industrial solvent and come on now seriously it’s such a pain in the ass do we REALLY have to do this?

    • I work for a machine shop. We make a lot of parts for the medical industry.

      We quit using 1,1,1-TCE years ago. Our degreasing agent of choise is a biodegrable water based product. Has been for many years.

  9. Density,
    Do you use Compact fluorescent lamps? Or regular fluorescent tubes. Ever break one? Better hope that you don’t. It requires a hazmat team for cleanup and removal.
    You don’t just throw them away do you? They are considered Universal Waste and must be decontaminated prior to disposal. Which company do you use for this?

    BTW 1,1,1 trichloroethane has been off the market for years.

    • CFLs don’t require hazmat teams to clean up.

      Industrial production that uses mercury in its process requires a hazmat team to clean up.

      And idiot housewives who watch too much daytime TV hear wild stories about mercury causing autism and panic when they break a light bulb.

      PS I don’t know about you, but we’ve got a warehouse full of 55-gallon drums of 1,1,1-TCE just in case we need it. You can get away with a lot when you’re part of the government’s strategic deterrence production industry!

  10. Every month, households all over NYC regularly deposit Infectious Waste into their garbage cans for the Sanitation Department to pick up and dispose of. There are no “Red Bags,” etc. “Universal Precautions” are obviously somewhat less than universal. Does this mean JCAHO will soon be making home visits?

  11. Just so we can get a baseline here, how many bags do other countries use? Anyone know? Must suck if their color code is different and you work internationally.

  12. Pingback: Episode 50: Subarachnoid Hemorrhage

  13. “Is there something about water treatment centers that can filter out sewage but that somehow misses vicodin pills? ”

    Actually there is. Water treatment plants use algae in huge outdoor tanks to “eat up” nitrates, then use bacteria to break down fiber and other undigestible substances. These 2 processes do nothing for unmetabolized medicines.

    If the water treatment plant uses activated charcoal filters before dumping the “treated” waste into your stream, then that would take out the meds. It all depends on the rules and budget the waste treatment plant is working with.

    This is such a big problem that my fishing magazine has studies on this sometimes. One study tested 6 streams in the US for about 10 unmetabolized meds. All streams had at least one medicine in it. Another study noted that male fish testes were actually producing eggs! How Frankenstein-weird is that?

    Another study tested peoples’ blood for a pharmaceutical metabolite, which acted as an endocrine disruptor. 90% of people tested positive for this substance.

  14. Better late to this party than never.

    Try chemotherapy on for size. One bucket for PPE, a separate bucket for the bags, tubing, syringes, etc.

    And what exactly are we doing with body fluids of patients on chemo (God forbid they should have any)? Let’s just say that not much has changed. 😉

    As always, right on WC!

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