Good practice guide to managing pharmaceutical wastes
Over the years, Remsol's experts have encountered dozens of situations where manufacturers of pharmaceuticals have gotten it wrong when it comes to describing their wastes for disposal purposes.
The use of accurate and fulsome waste descriptions has long been enshrined in UK environmental laws, but in 2004 it also became necessary to describe wastes by reference to a 6-digit code from the European Waste Catalogue (EWC).
Correct use of the EWC is patchy at best, with many companies failing to select the most appropriate code for their wastes - not helped by sector-specific guidance on the topic that many complain seems disconnected from the manufacturing environment and targeted more towards the safe disposal of medicines arising in hospitals and from patient use.
In some cases, improper coding of waste has encouraged the wrong decisions to be made about how pharmaceutical waste is disposed of and there are examples of finished rejects being illegally disposed of.
The Environment Agency is so concerned about these issues that it asked Remsol to consider hosting a seminar event aimed at raising the importance of using the correct descriptions and EWC codes, as well as confirming the disposal routes that are acceptable - and those which are not and could lead to prosecution.
Lee Petts, managing director at Remsol, was delighted to be asked to host such an event: "There is so much confusion out there still, that a seminar which promotes 'joined-up-thinking' and helps businesses in the UK pharmaceutical and biotech sectors to get and stay compliant with relevant waste laws is probably long overdue," says Lee.
Accepting the challenge, Remsol has also decided to address a number of other, related topics in the seminar planned for May 2010, including:
- how ADR requirements relate to shipments of pharmaceutical wastes
- what the legal consequences are of failure to comply with relevant waste laws, and possible legal defences
- how to get best value from waste management arrangements
Lee concludes "Bringing together the expert opinions of relevant industry regulators such as the Environment Agency, HSE and Department for Transport, as well as advice from top City law firm Travers Smith and our own experiences of what constitues good practice, this event should finally provide that elusive and concrete guidance that waste producers need to make informed choices."
The date and exact venue for the seminar are yet to be finalised, but it is expected to take place in May 2010 in London or elsewhere in the South of England.
Individuals wishing to attend can pre-register by contacting amanda.thresh@remsol.co.uk using the title: "PWM pre-reg" and will receive confirmation of costs and full booking details as soon as these are available.
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