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1. Purpose
This SOP describes the procedures to be used for the disposal of unusable pharmaceutical products
in accordance with WHO "Good Distribution Practices" (GDP) and good environmental and public
health practices. The disposal of product includes technical issues managed through the Principal
Waste Management Advisor, financial issues managed through the Global Inventory Manager (GIM),
and contract issues managed through the Senior Contracts Officer. Any use of USG funding for
disposal including SCMS staff time must have the concurrence of the USAID, or applicable client,
obtained through the SCMS Contract Manager.
2.Scope
The scope of this SOP applies to all SCMS-supported activities to control and confirm the disposal of
unusable pharmaceutical products whether USG-owned in SCMS custody or assisting at the client's
request in the disposal of client-owned pharmaceuticals. This SOP may be adopted or adapted by the
host country or other clients to help ensure that safe health and environmental standards are
maintained for the disposal of their unusable pharmaceutical products provided the quality measures
are retained.
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Standard Operating Procedure
F-QSU-002--002-01
3 . Respons1"bTti
11 es
Title Responsibility
On a routine basis, identifies and quarantines any USG-owned
pharmaceutical waste in SCMS custody. Creates pharmaceutical disposal
list. Requests authorization for disposal of pharmaceutical waste from
Procurement, USG, GIM, and Principal Waste Management Advisor, and
Responsible Pharmacist USAID concurrence through SCMS Contract's Officer. Arranges, in
orSCMS coordination with local and national regulatory authorities, for the removal
designee/Regional of pharmaceutical waste and arranges for the disposal with an appropriate
Distribution Center contractor. The USG representative and SCMS designee witness and
Manager or FFL document the disposal. Retains copies of pharmaceutical disposal list,
disposal authorizations, disposal certificate, and receipt for disposal
services. Files all documents in SCMS Knowledge Tree (KT) archive in
the Quality Assurance/Waste Management Folder under Hazardous
Waste in the named country file.
Reviews disposal inventory, proposed disposal methods, local and
Principal Waste national regulatory authority concurrences, and issues approval for the
Management Advisor disposal protocol. Notifies Contracts Manager when all required
documents are posted on SCMS KT.
Authorizes disposal of USG-owned product in SCMS custody and
forwards lists to the Senior Contracts Officer and Contracts Manager to
Global Inventory resolve liability/insurance options and obtain USAID concurrence when
Manager (GIM) applicable GIM periodically reviews recordkeeping during site visits to
ensure that it is maintained.
Provides GIM with the original destruction certificate with a copy to the
Assistant FFL
Principal Waste Management Advisor, in situations in which the waste is
Operations Coordinator an SCMS- provided product.
Reviews Retention Store analytical sample expiry date reports at least
Quality Control (QC) quarterly. Schedules disposal of products at least one month past expiry
Specialist dates.
For USG-owned products in SCMS custody which are unusable, reviews
Senior Contracts Officer causes of damage to determine possible vendor or shipper liability for
SCMS insurance claims.
For USG goods in SCMS custody and expenditure of SCMS funds for
Contracts Manager disposal, obtains concurrence for disposal.
4. Definitions
Term Definition
Defined as such by the pharmaceutical regulatory authority, a substance
Controlled substance which requires special handling, normally under the supervision of a
pharmacist.
Inert A substance that is not chemically active or hazardous.
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Standard Operating Procedure
F asu-002-002-01
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Standard Operating Procedure
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Background
During the course of pharmaceutical distribution, products are occasionally damaged or are held past
their expiration date and are no longer useable. Pharmaceutical waste may also result from periodic
"de-junking" or routine inventory clearance processes. Pharmaceutical waste is no longer medicine; it
is chemical waste and must be disposed of in an environmentally safe and permanent manner. When
SCMS staff is involved in the disposal, it is important for them to monitor and ensure that the disposal
of unusable pharmaceuticals is conducted using a well-documented procedure that ensures both the
employee and public safety, and poses minimal risk to the environment.
This set of Standard Operating Procedures (SOP) and Work Instructions (WI) are intended for any
SCMS staff members or contractors who may become involved in disposal procedures. SCMS staff
members or contractors may become involved in the disposal of unusable pharmaceutical products in
one of two scenarios:
1. The Responsible Pharmacist/RDC/Freight & Logistics (F&L) or designate will identify and
quarantine pharmaceutical waste in a secure area inaccessible to unauthorized personnel and
protected from the weather.
2. For USG-owned products in SCMS custody, the Responsible Pharmacist or F&L manager will
prepare a proposed Pharmaceutical Disposal List (F-QAU-007-001 or F-QAU-007-002) with
the following information:
a. Product description, including manufacturer
b. Strength
c. Presentation
d. Units
e. Quantity/volume
f. Batch number
g. Responsible Pharmacist or FFL manager signature.
3. The Responsible Pharmacist/RDC or responsible SCMS-designee forwards the proposed
Pharmaceutical Disposal List, disposal protocol and local and national regulatory authority
concurrences to the Senior Contracts Officer, Contracts Manager and Global Inventory and
Principal Waste Management Advisor.
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Standard Operating Procedure
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4. If the reason for destruction is damage possibly due to vendor or shipper negligence then an
incident report shall be filed to prompt an investigation. The Senior Contracts Officer reviews the
causes of damage and determines if there is vendor or shipper liability for the damages, and if
so the Contracts Officer files claims. If there is no shipper or vendor liability the Senior
Contracts Officer investigates filing an insurance claim for the damages. After the Senior
Contracts Officer concludes that investigation the Principal Waste Management Advisor
reviews the proposed disposal protocol to assure that they meet SCMS standards and if so,
approves them and forwards the document to the GIM for approval. Following the GIM
approval the list is forwarded to Contracts Manager to obtain USAID concurrence.
5. After the USAID concurrence is obtained, the approved Pharmaceutical Disposal List is sent to
the Responsible Pharmacist/RDC or SCMS designate who authorizes the disposal in
accordance with the approved protocols.
6. The QC Specialist conducts quarterly reviews of the expiry date report for analytical samples
stored in the Retention Store, to identify those which have passed their expiry date plus at
least 1 month. The proposed disposal list is sent to the Product Quality Manager for approval.
After approval has been obtained, the QC Specialist will take the samples to North-West
University (NWU) under chain of custody for disposal. The samples will be disposed by NWU
in accordance with applicable procedures - the disposal and removal of pharmaceutical,
chemical, medical, and other bulk waste.
6.2 Procedures for Disposal of Unusable Pharmaceutical Products
1. If disposal resources are not available in the country and/or export is not permitted, contact the
Deputy Director, Global Supply Chain or the Principal Waste Management Advisor.
2. The Responsible Pharmacist, SCMS designate, or RDC Manager issues a Request-for-
Proposal (RFP) to identify a waste processing service or contractor to perform the defined
disposal, taking into account national and local standards and the disposal capacity available
in country. The solicitation may be limited to companies on an approved list provided by the
client and, upon identifying an appropriate disposal firm, issues the contract in compliance with
the Federal Acquisition Regulations (FARS) and national law. The Responsible
Pharmacist/SCMS designate will specify in the RFP that only waste disposal companies that
adhere to national and local waste management regulations and have permits and approvals
required by the appropriate authorities will be considered. The selected company must provide
to SCMS verification of those authorizations in writing.
3. The Responsible Pharmacist, SCMS designate or RDC Manager will arrange with the
contracted waste processing contractor to remove the waste identified for disposal after
approval has been received from the national and local authorities, the indicated SCMS
officers and the USAID. The Responsible Pharmacist or designate will accompany the goods
to the disposal site, witness the disposal and obtain a copy of the Disposal Certificate.
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Standard Operating Procedure
F-QSU-002-002-01
4. The SCMS Global Inventory Manager adjusts the stock level as necessary in Orion once it has
been authorized. The cost of the destruction process will be retained in Knowledge Tree in the
QANVaste Disposal/Hazardous Waste folder, in the appropriate country folder, for monitoring
purposes.
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Standard Operating Procedure
F-OSU--002--002--01
SCMS recognizes that discharge into a sewer is also a common disposal practice in some
countries, but as a matter of policy SCMS does not support this procedure except in rare cases for
products which do not contain active pharmaceutical ingredients, e.g., saline-based parenteral
solutions.
The SCMS Responsible Pharmacist or designate is responsible and accountable to ensure that
the waste disposal method and location selected is in accordance with the technical guidelines
listed herein.
Where acceptable disposal methods are not available in country, the Responsible Pharmacist or
designate will contact the Global Inventory and Product Quality Assurance Managers to negotiate
the possibility of exporting the unusable pharmaceuticals to appropriate disposal facilities in
compliance with the Basel Convention rules.
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Standard Operating Procedure
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7. Records
1. F-QAU-007-001-SCMS Product Disposal List
2. F-QAU-007-002-Non-SCMS Product Disposal List
8. Distribution
1. QAU Staff
2. Knowledge Tree
9. Annex Documents
1. Attachment 1: Training Evaluation Checklist
2
3
4
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Standard Operating Procedure
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Attachment 1
TRAINING EVALUATION CHECKLIST
To ensure complete understanding, please answer the following questions on this SOP.
4. T/F The Pharmacists must quarantine pharmaceutical waste so that it is not distributed.
COMPLETED BY:
---------
EVALU ATE D BY:
SUCCESSFUL: YES/NO
EMPLOYEE:
DEPT MGR:
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