Stewardship for Sharps and Reusable Sharps Containers - Business Case Considerations December 2020

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Stewardship for Sharps and Reusable Sharps Containers - Business Case Considerations December 2020
Stewardship for
Sharps and Reusable
Sharps Containers
Business Case Considerations
December 2020

 1   Stewardship for Reusable Sharps Containers – Business Case Considerations
Stewardship for Sharps and Reusable Sharps Containers - Business Case Considerations December 2020
CONTENTS
Glossary                                              i
Executive Summary                                    ii
Introduction                                        01
Product Stewardship and EPR                        02
The Need for Sharps Stewardship                    03
Additional Issues for Sharps Stewardship           04
Conclusions                                        09
References                                          10

GLOSSARY
Background Paper Stewardship for Sharps and Reusable Sharps Containers – Background and Issues Paper
DASTRI                (France) EPR system for home-generated sharps
DfE                   Design for Environment
DSC                   Disposable Sharps Container
EPR                   Extended Producer Responsibility
GHG                   Greenhouse Gas
GlobalPSC             Global Product Stewardship Council
IPR                   Inevitable Policy Response
OECD                  Organisation for Economic Co-operation and Development
RSC                   Reusable Sharps Container
WHO                   World Health Organization

 i     Stewardship for Reusable Sharps Containers – Business Case Considerations
Stewardship for Sharps and Reusable Sharps Containers - Business Case Considerations December 2020
EXECUTIVE SUMMARY

THIS REPORT IS INTENDED TO    SHARPS PROGRAM                               Redesign, reuse and recycling
ASSESS CURRENT BUSINESS                                                    are not viable options for sharps
                              OVERVIEW
CASE CONSIDERATIONS                                                        themselves at this stage, given
FOR REUSABLE SHARPS                                                        specific medical and regulatory
                              Increased demand for home
STEWARDSHIP MODELS FOR                                                     requirements, but represent
                              healthcare, underscored by the
THE HOME HEALTHCARE                                                        significant potential opportunities
                              COVID-19 pandemic, will continue
INDUSTRY, AND BUILDS UPON                                                  for growth in these areas as part
                              to drive the increased generation
THE ACCOMPANYING GLOBAL                                                    of reducing risks while meeting
                              of household-generated sharps
PRODUCT STEWARDSHIP                                                        growing demand. Regulatory
                              such as used needles, lancets and
COUNCIL (GLOBALPSC) REPORT,                                                frameworks, including product
                              similar devices, with the resultant
STEWARDSHIP FOR SHARPS AND                                                 stewardship / EPR programs,
                              need for the safe collection and
REUSABLE SHARPS CONTAINERS                                                 should allow for flexibility as
                              management of sharps.
– BACKGROUND AND ISSUES                                                    technology and program design
PAPER (BACKGROUND                                                          evolve. Although this is an area
                              RSCs are used in Australia, USA,
PAPER). THE BACKGROUND                                                     for further development, EPR
                              UK, New Zealand, South Africa,
PAPER COMPARES REUSABLE                                                    programs should consider the use
                              Canada, South America, and by
SHARPS CONTAINERS (RSCS)                                                   of RSCs more closely as a viable
                              the World Health Organization
TO DISPOSABLE SHARPS                                                       option to reducing the waste
                              (WHO) and Medecins Sans
CONTAINERS (DSCS) FOR                                                      associated with sharps disposal
                              Frontieres. However, current RSC
HOME HEALTHCARE USE, AND                                                   and its carbon impact.
                              usage is predominantly in hospital
HIGHLIGHTS OPPORTUNITIES TO
                              and clinical settings; examples of
INTEGRATE RSCS IN PRODUCT
                              the use of RSCs in the home and
                                                                           RISKS OF SHARPS
STEWARDSHIP AND EXTENDED
                              residential care settings have not           WASTE
PRODUCER RESPONSIBILITY
                              been identified outside of those
(EPR) APPROACHES.                                                          Perceived risks to waste
                              being initiated by HealthBeacon.
                                                                           management and recycling
FOR BOTH REPORTS,                                                          workers are often cited for
                              All existing programs for home
HEALTHBEACON COMMISSIONED                                                  introducing sharps product
                              healthcare sharps focus on
THIS GLOBALPSC RESEARCH                                                    stewardship / EPR. However, as
                              ensuring proper management
TO UPDATE THE GLOBALPSC’s                                                  detailed in the Background Paper,
                              and disposal through autoclaving
2016 REPORT FOR THE US                                                     research shows that actual risks
                              (steam sterilization), incineration
HEALTHCARE INDUSTRY ON                                                     to these workers of infectious
                              or landfilling in the interests
PRODUCT STEWARDSHIP AND                                                    disease transmission are quite
                              of consumer safety and the
EPR PROGRAMS FOR SHARPS.                                                   low. The greater risks, however
                              environment.
                                                                           appear to lie with family members
                                                                           of sharps users. An approach
                                                                           specifically addressing household
                                                                           sharps users and their caretakers
                                                                           could therefore provide greater
                                                                           safety if made convenient and
                                                                           accessible.

                                Stewardship for Reusable Sharps Containers – Business Case Considerations   ii
Stewardship for Sharps and Reusable Sharps Containers - Business Case Considerations December 2020
EXECUTIVE SUMMARY

LIFE-CYCLE BENEFITS OF RSCs

Both DSCs and RSCs are essential in healthcare.                   Sharps users lacking appropriate education frequently
Although life-cycle data on home healthcare for RSCs              dispose of sharps loosely in the household trash or
is not currently available, peer-reviewed studies on              into toilets.
RSC use in hospitals show that RSCs may help to
eliminate almost all sharps plastic that is currently             Where they exist, product stewardship and EPR
landfilled, greatly reduce greenhouse gas emissions,              approaches for sharps in home healthcare do not fully
significantly reduce sharps injuries and reduce labour.           consider the potential roles of RSCs. However, viable
                                                                  reuse systems should be rolled out in cooperation
These benefits are possible while still keeping risks to          with the introduction of products onto the market, as
public health and safety low, as both DSCs and RSCs               part of individual producers’ responsibility under these
are designed, manufactured and tested to the same                 approaches.
high standards. Expanding use of RSCs into home
healthcare would therefore be consistent with circular            To date, waste in the medical industry has typically
economy and sustainability principles if part of robust,          been incinerated, but as carbon budgets tighten
managed collection, processing and reuse initiatives              and the clear effects of climate change force action,
coupled with appropriate education and outreach to                this will no longer be considered a long-term viable
patients and carers. Indeed, patient management of                solution. A move to reuse and recycling will become of
sharps is highly dependent on the level of education              paramount importance.
they receive.

  iii    Stewardship for Reusable Sharps Containers – Business Case Considerations
Stewardship for Sharps and Reusable Sharps Containers - Business Case Considerations December 2020
INTRODUCTION

This report is intended to highlight          Comparison of reusable sharps                   HealthBeacon’s FDA-cleared Smart
business case considerations                  containers (RSCs) against                       Sharps Bin tracks patient injection
for reusable sharps stewardship               disposable sharps containers                    history, provides personalized
models for the home healthcare                (DSCs) and opportunities to                     interactive reminders and safely
industry, and builds upon the                 integrate RSCs into product                     stores used injections. With the
accompanying Global Product                   stewardship and EPR approaches                  intervention of HealthBeacon’s
Stewardship Council (GlobalPSC)               are specific areas of focus for the             Smart Sharps Technology, patients’
report Stewardship for Sharps                 Background Paper.                               persistence and adherence
and Reusable Sharps Containers                                                                increased by 25-30% within twelve
– Background and Issues Paper                 ABOUT THE GLOBALPSC                             months of initiating therapy.
(Background Paper).                                                                           HealthBeacon’s integrated model
                                                                                              connects a patient’s routine and
                                              The GlobalPSC is an independent,
HealthBeacon1 has funded this                                                                 the prescribing clinician’s workflow.
                                              not-for-profit organization
report to update the GlobalPSC’s                                                              This technology has been adopted
                                              dedicated to facilitating the
2016 background research (2016                                                                across 13 countries with >400,000
                                              development of effective product
Report or GlobalPSC 2016) on                                                                  injections tracked since launch in
                                              stewardship and EPR schemes
global product stewardship and                                                                2014, and a patient acceptance
                                              globally. The GlobalPSC has
Extended Producer Responsibility                                                              rate of 80-90%.
                                              members operating worldwide
(EPR) programs for sharps
                                              that span producers, product
and unwanted or out-of-date,                                                                  HealthBeacon follows the EPR
                                              recovery organizations,
medicines. The 2016 Report                                                                    model as a part of its fundamental
                                              reprocessors, NGOs, universities
was funded by Eli Lilly and                                                                   business model, embracing end to
                                              and governments at federal, state
Company in support of facilitated                                                             end product stewardship. Earlier
                                              and local levels.
discussions between the US                                                                    this year, HealthBeacon launched
pharmaceutical industry and key                                                               its innovative Green Labs initiative
stakeholders.                                 ABOUT HEALTHBEACON                              for sustainable waste management.
                                              AND THE HB GREEN                                The labs which HealthBeacon have
The Background Paper addresses                LABS                                            built will allow for the sterilisation
adoption and significance of                                                                  and reuse of sharps bins and
public health and safety concerns,                                                            recovery of injection waste for
                                              HealthBeacon is a medication
the circular economy and reuse                                                                more sustainable processing.
                                              adherence technology company
for sharps.                                   which develops smart tools for
                                              managing medication.

  1                                             Disclosure:
                                                  1
         Stewardship for Reusable Sharps Containers         HealthBeacon
                                                     – Business          (www.healthbeacon.com) is a GlobalPSC Corporate member.
                                                                  Case Considerations                                              1
Stewardship for Sharps and Reusable Sharps Containers - Business Case Considerations December 2020
PRODUCT STEWARDSHIP AND EPR

PRODUCT STEWARDSHIP IS AN ENVIRONMENTAL                           IMPACTS ON DFE AND SUPPLY CHAINS
MANAGEMENT STRATEGY TO PROMOTE INCREASED
RESPONSIBILITY FOR THOSE WHO DESIGN,
                                                                  While EPR has delivered a variety of benefits across
PRODUCE, SELL OR USE A PRODUCT, TO MINIMIZE
                                                                  product types, its direct impact on a primary objective,
THAT PRODUCT’S ENVIRONMENTAL IMPACT.
                                                                  DfE, has been quite limited overall and focused mainly
MOST MODELS AIM TO SHIFT SOME PHYSICAL
                                                                  on packaging design considerations. Design for
AND/OR FINANCIAL RESPONSIBILITY FROM STATE
                                                                  environment is also more viable in consumer products
AND LOCAL GOVERNMENTS TO PRODUCERS
                                                                  with more rapid design turnover, such as packaging
AND CONSUMERS OF SPECIFIC PRODUCTS
                                                                  and e-waste. (OECD 2016)
(TRADITIONALLY FOR PACKAGING AND E-WASTE
BUT INCREASINGLY APPLIED TO A WIDE RANGE OF
                                                                  Various product stewardship and EPR programs are
PRODUCTS).
                                                                  working to integrate more of a circular economy
                                                                  approach in which the value of products, materials and
The Organisation for Economic Co-operation and
                                                                  resources is maintained in the economy for as long as
Development (OECD) defines EPR as (OECD 2014):
                                                                  possible, and the generation of waste is minimized.
                                                                  Broader circular economy approaches, such as the EU
  “...an environmental policy approach in which                   action plan for the circular economy and the French
  a producer’s responsibility for a product is                    Roadmap for the Circular Economy, increasingly
  extended to the post-consumer stage of a                        integrate stewardship and EPR. (European Commission
  product’s life cycle.”                                          2015) (OECD 2016) (Republic of France 2018)

                                                                  The home healthcare industry has opportunities to
Shifting responsibility through EPR is intended to drive
                                                                  develop circular economy models that provide both
improvements in design for environment (DfE), an
                                                                  significant life-cycle and circular economy benefits
approach that attempts to reduce a product’s overall
                                                                  overall, while potentially reducing supply chain risks,
impacts on human health and the environment.
                                                                  and disruptions, and addressing potential resource
                                                                  scarcity through resource management and control.
Responsibility is invariably shared across a range of
stakeholders, including consumers. Program costs,
however, are generally incorporated into purchase
prices so that consumers are not charged when they
return items at end-of-life.

  2      Stewardship for Reusable Sharps Containers – Business Case Considerations
THE NEED FOR SHARPS STEWARDSHIP

With sharps used in the treatment                  Although ‘needle-free’ insulin                     challenges accessing medications
and management of various                          delivery methods are under                         and healthcare providers. Some
conditions, including one of the                   development, such approaches                       patients deemed ‘high-risk’, taking
leading causes of morbidity                        are not likely to be available for                 medications which suppress their
worldwide, diabetes, there is                      the foreseeable future (Diabetes.                  immune system, may have been
significant need for enhanced                      co.uk, 2020). Diabetes-related                     instructed to pause their treatment
sharps stewardship. Against the                    products account for 80-90% of                     during this pandemic, with the
background of the COVID-19                         the materials recovered through                    resultant impact on their adherence.
pandemic, with remote care                         the French sharps EPR program,                     The extremely valuable data that
in the home setting growing,                       DASTRI2.                                           HealthBeacon provides enables
such stewardship is becoming                                                                          targeted intervention programs and
increasingly necessary.                            IMPACTS OF THE                                     an additional level of support for
                                                   COVID-19 PANDEMIC                                  these high-risk patients.
SIGNIFICANCE OF                                                                                       SHARPS MANAGEMENT
DIABETES                                           As the full impact of the COVID-19
                                                   pandemic comes to light, it                        AND DISPOSAL PRACTICES
                                                   is clear that its impact on the
According to the World Health
                                                   home healthcare industry will                      Most references show high
Organization (WHO), globally
                                                   be significant. Factors such                       rates of direct sharps disposal
around 422 million adults were
                                                   as increased home isolation                        into household trash, although
living with diabetes in 2014, a
                                                   and minimization of travel and                     information on whether the sharps
significant increase from the
                                                   exposure at medical facilities                     were contained prior to this disposal
108 million living with diabetes
                                                   may have lasting effects on                        is limited.
in 1980. The age-standardized
                                                   healthcare as we know it, and
global prevalence of diabetes has
                                                   increase the burden on remote                      Four US states (California,
nearly doubled in adults, rising
                                                   patient care. The collection,                      Massachusetts, Oregon and
from 4.7% in 1980 to 8.5% in 2014.
                                                   transport and handling of sharps                   Wisconsin) and the Canadian
Over the past decade, diabetes
                                                   from home healthcare will also                     province of Ontario allow medical
prevalence has risen faster in low-
                                                   likely be impacted as a result.                    waste generators such as
and middle-income countries than
                                                   However, these conditions                          hospitals and other institutions
in high-income countries. (WHO
                                                   could also generate commercial                     to dispose of sharps as general
2016)
                                                   opportunities.                                     solid waste in landfills if treated to
                                                                                                      be non-infectious/non-hazardous
The WHO estimates that diabetes
                                                   HealthBeacon’s Smart Sharps                        (autoclaving is common practice);
caused 1.5 million deaths in 2012,
                                                   Bin has been implemented                           this provides for no additional risk
with higher-than-optimal blood
                                                   across 13 markets including the                    of exposure. Apart from Oregon
glucose causing an additional
                                                   USA, Canada, Germany, Italy,                       allowing a de minimus 50 pounds
2.2 million deaths, with 43% of
                                                   Belgium, Netherlands, Ireland,                     per month exemption from prior
these 3.7 million deaths occurring
                                                   Portugal, Israel, South Africa,                    treatment requirements, these
before 70 years of age. (WHO
                                                   Luxembourg, Latvia and Lithuania.                  jurisdictions do not allow for
2016)
                                                   With thousands of active users                     landfilling of sharps containers
                                                   across different continents, many                  without prior treatment. This raises
This high burden of disease
                                                   of these patients on injectable                    the question as to the need for
comes with a high demand for
                                                   medications are considered high-                   treatment of home-generated
treatment, resulting in significant
                                                   risk if they contract the COVID-19                 sharps where infectious disease
use of insulin needles. Diabetes
                                                   virus. From their digital-enabled                  transmission is different, as
however is not the only disease
                                                   Sharps Bin, HealthBeacon has                       discussed further in the Background
for which patients take injectable
                                                   been able to detect a trend                        Report.
therapy in the home setting.
                                                   towards higher rates of non-
Indeed, an estimated 9 million
                                                   adherence in some injectable
people in the US use sharps at
                                                   medications in 2020 compared to
home, resulting in more than
                                                   previous years. The reasons for
3 billion disposable needles
                                                   this are varied and may include
and syringes and 900 million
                                                   delays to treatment start dates,
lancets each year being disposed
                                                   postponed hospital appointments,
(safeneedledisposal.org, 2020).

 DASTRI-related information is based on personal communication with Laurence Bouret, Déléguée Générale for DASTRI from 2016 to 2020, unless
    3                                                                                                                                         3
2

otherwise indicated.
             Stewardship for Reusable Sharps Containers – Business Case Considerations
ADDITIONAL ISSUES FOR SHARPS STEWARDSHIP

REUSABLE VS                               USE OF REUSABLE                          ENVIRONMENTAL
DISPOSABLE SHARPS                         SHARPS CONTAINERS                        IMPACT OF RSCS
CONTAINERS
                                          Commercial RSCs were first               Both DSCs and RSCs are essential
ALTHOUGH RSCS ARE A                       used in US and Australian                in healthcare. Although life-cycle
MORE SUSTAINABLE OPTION                   hospitals in 1986, and now               data on home healthcare for RSCs
COMPARED TO DSCS, THEIR                   represent approximately 50%              is not currently available, peer-
USE INVOLVES A NUMBER                     and 75%, respectively, of the            reviewed studies on RSC use in
OF KEY CONSIDERATIONS, IN                 sharps containers used in these          hospitals show that RSCs may
PARTICULAR RELATING TO                    countries. Since 1999, RSCs have         (Grimmond, 2019):
POTENTIAL PUBLIC HEALTH                   been increasingly used in Canada,
RISKS.                                    UK, Ireland, New Zealand, South
                                          Africa and South America. RSCs           99%
IN RESEARCH AND                           are also used by the WHO                 Eliminate 99% of sharps plastic
CONSULTATIONS FOR THIS                    and Medecins Sans Frontieres.            landfilled;
REPORT, THE GLOBALPSC                     (Grimmond, 2019) (McPherson et
COULD NOT CONFIRM THE
ADOPTION OF RSCS FOR
                                          al, 2019)
                                                                                   65-84%
HOME HEALTHCARE USE                       TESTING OF RSCS                          Eliminate 65-84% of Greenhouse
OUTSIDE OF THE SYSTEM                                                              Gas (GHG) emissions;
BEING IMPLEMENTED BY                      RSCs can be reused many
HEALTHBEACON. EVEN                        times per year and may be in
DATA ON RSC USAGE WITHIN                  use for several decades with
HEALTHCARE FACILITIES IS                  appropriate manufacture, usage           Significantly reduce sharps
QUITE LIMITED. ADDITIONAL                 and maintenance. The US FDA              injuries;
RESEARCH WILL THEREFORE                   requires both RSCs and DSCs
BE NECESSARY TO DETERMINE                 to pass identical performance
ATTRIBUTES SPECIFIC TO HOME               tests and design requirements
HEALTHCARE USE. NOTE, ALL                 under relevant standards. Prior          Reduce labour.
LIFE-CYCLE INFORMATION                    to this testing, the US FDA also
ON RSCS THAT FOLLOWS                                                               These benefits are possible while
                                          requires ‘‘lifespan simulation’’
IS BASED IN HOSPITAL                                                               still keeping risks to public health
                                          of RSCs, which includes filling
OR SIMILAR HEALTHCARE                                                              and safety low.
                                          and processing for the number
SETTINGS INSTEAD OF HOME                  of lifespan uses stated by the
HEALTHCARE, DUE TO THE                    manufacturer (e.g., 500 times)
LIMITED INDEPENDENT, PEER-                and transport vibration tests
REVIEWED DATA AVAILABLE.                  such as the US Department of
                                          Transport Packaging Vibration
                                          Standard to ensure robustness
                                          during transit. The Canadian
                                          sharps container standard
                                          involves similar requirements.
                                          (McPherson et al, 2019)

 4     Stewardship for Reusable Sharps Containers – Business Case Considerations
ADDITIONAL ISSUES FOR SHARPS STEWARDSHIP

FIT WITHIN CIRCULAR
ECONOMY PRINCIPLES

While various healthcare facilities   The 2019 study examined the                 Under circular economy
adopted RSCs for sustainability       impact on GHG of nation-wide                principles, the value of products,
reasons, quantitative studies         transport distances when a large            materials and resources is
for this are rare. While limited      US teaching hospital system                 maintained in the economy
quantitative data is available,       converted from DSCs to RSCs.                for as long as possible, the
recent life-cycle analysis            The RSCs in the study were                  generation of waste is minimized
comparing RSCs and DSCs in a US       certified for 500 uses and reused           and landfilling is avoided, where
hospital (McPherson et al, 2019)      an average of 12 times/year,                possible. Higher-value uses are
found that:                           for a theoretical ‘‘end-of-life’’           regularly sought, rather than
                                      lifespan of 41.7 years. However,            downcycling and disposal. Rather
- RSCs achieved significant GHG       a ‘‘worst-case’’ lifespan scenario          than an end-of-life perspective
reductions over DSCs, even where      of 26.4 years based on the most             and a focus on material recovery,
large RSC transport distances         frequently used RSC still in service        circular economy takes a life-
lessen the GHG differential           in the US was assumed for the               cycle perspective and spans
between the two systems               study. The study confirmed                  entire supply and recovery chains.
                                      that large transport distances              Many newer circular economy
- Transport and electricity           between polymer manufacturer,               initiatives also seek to minimize
cleanliness (e.g., renewables         container manufacturer, user                the manufacture of, or maximize
vs coal) are key factors in GHG       and processing facilities, can              the reuse of, plastics and
emissions for RSC systems             significantly impact the carbon             integrate product stewardship
                                      footprint of sharps containment             and EPR. (European Commission
- The lifespan of RSCs has minimal    systems. (McPherson et al, 2019)            2015) (OECD 2016) (Republic of
effect when comparing carbon                                                      France 2018)
footprint between the two             Converting to RSCs, the hospital
systems                               system examined reduced its                 Given the benefits of RSCs
                                      annual GHG by 162.4 tonnes                  shown earlier, expanding the use
- Purchasing decisions can            CO2-eq, a 65.3% reduction. They             of RSCs into home healthcare
significantly contribute to GHG       also had an annual elimination of           would therefore be consistent
reduction strategies.                 50.2 tonnes of plastic DSC and              with circular economy and
                                      8.1 tonnes of cardboard from the            sustainability principles if part
- Institution-wide adoption of        sharps waste stream. Of the DSC             of robust, managed collection,
RSCs can reduce GHG with              plastic eliminated, 31.8 tonnes             processing and reuse initiatives
minimal staff behavior-change.        were diverted from landfill and             coupled with appropriate
                                      18.4 tonnes were diverted from              education and outreach to
                                      incineration. (McPherson et al,             patients and carers.
Annual GHG emissions by life          2019)
stage (with DSCs normalized to
Adjusted Patient Days) are shown
in Figure 1.

A previous study had found that
converting from DSCs to RSCs
reduced sharps waste stream
GHG by 84%. However, the 2019
study confirmed that transport
distances impacted significantly
on GHG outcomes.

                                                        Figure 1: Annual GHG emissions by life stage
                                                                   (McPherson et al, 2019)

                                        Stewardship for Reusable Sharps Containers – Business Case Considerations   5
ADDITIONAL ISSUES FOR SHARPS STEWARDSHIP

PUBLIC HEALTH AND SAFETY                                         INTEGRATION WITH PRODUCT
                                                                 STEWARDSHIP AND EPR
Most of the public health and safety considerations
around sharps containers revolve around increasing               Where they exist, product stewardship and EPR
the appropriate use and management of approved                   approaches for sharps from home healthcare do not
sharps containers through access, convenience                    fully consider the potential roles of RSCs. However,
and education, regardless of whether the sharps                  viable reuse systems should be considered and
containers are disposable or reusable. Both RCSs                 rolled out in cooperation with product manufacturers
and DSCs are made to perform to the same high                    as individual producer responsibility under these
standards, and reuse systems are designed to                     approaches.
minimize human contact. Various studies have
confirmed that RSCs represent no greater risk than               Determining collection data for sharps can pose
DSCs. (Grimmond, 2019)                                           difficulties, as highlighted for Ontario and DASTRI
                                                                 in the Background Paper. While material collections
                                                                 from a given jurisdiction can ultimately be determined,
                                                                 the amount of product sales into a given jurisdiction
                                                                 (especially at a state or local level) can be difficult to
                                                                 determine given existing distribution networks. The
                                                                 durability and tracking possible for RSCs should help
                                                                 avoid many of these problems experienced by product
                                                                 stewardship and EPR programs, as long as the process
                                                                 and tracking are explained clearly.

  6     Stewardship for Reusable Sharps Containers – Business Case Considerations
ADDITIONAL ISSUES FOR SHARPS STEWARDSHIP

OTHER CONSIDERATIONS – THE
INEVITABLE POLICY RESPONSE

The landscape for stewardship of sharps and sharps          Waste in the medical industry has typically been
containers is chaotic and fragmented at the moment,         incinerated, but as carbon budgets tighten and the
but governments around the world are coming to              clear effects of climate change force action, this will
the realization that waste will need to be tackled and      no longer be considered a long-term viable solution. A
legislated in a more cohesive and globalized manner.        move to reuse and recycling will become of paramount
                                                            importance.
The medical industry is not escaping scrutiny, and
as it becomes clear that the pandemic has greatly           Along with the tightening of financial regulations will
increased single use plastics and medical waste, the        come the scrutiny of supply chains and the inevitable
risk of a strong policy response is becoming inevitable.    tightening of regulations around waste. It is therefore
                                                            advantageous for those who are aware of these
In financial circles, this phenomenon, known as the         coming changes to get ahead of the curve, make
inevitable policy response (IPR), predicts a sharp and      the necessary changes in an orderly fashion, and
disruptive government response to the climate crisis        position themselves as leaders in the new circular and
the closer we get to 2025.                                  sustainable economy.

     “Government action to tackle climate change has so far been highly insufficient
        to achieve the commitments made under the Paris Agreement, and the
       market’s default assumption appears to be that no further climate-related
       policies are coming in the near-term. Yet as the realities of climate change
      become increasingly apparent, it is inevitable that governments will be forced
                      to act more decisively than they have so far.

       The question for investors now is not if governments will act, but when they
       will do so, what policies they will use and where the impact will be felt. The
        IPR project forecasts a response by 2025 that will be forceful, abrupt, and
                      disorderly because of the delay.” (UNPRI 2020)

                                          Stewardship for Reusable Sharps Containers – Business Case Considerations   7
ADDITIONAL ISSUES FOR SHARPS STEWARDSHIP

AREAS FOR FURTHER EXPLORATION

GIVEN THE SCARCITY OF DATA ON REUSABLE
SHARPS SYSTEMS FOR HOME HEALTHCARE, THE
GLOBALPSC RECOMMENDS THAT THE FOLLOWING
AREAS BE EXAMINED TO BETTER DEFINE THE
BUSINESS CASE FOR THESE SYSTEMS:

1. Define collection and transport models for RSCs               6. The healthcare sector is heavily regulated and
used in home healthcare, including ground and air                scrutinized by governments at all levels. Therefore,
transport, and including mailback options specifically.          the development of a government relationship road
                                                                 map plan would inform a better understanding of
2. Life-cycle analysis of processing and                         government departments that influence the sector.
decontamination systems such as HealthBeacon’s                   From this, a sphere of influence and targeted
Green Labs, factoring in specific collection and                 relationship-building exercise between the home
transport models.                                                healthcare sector and government departments can
                                                                 begin e.g. Dept. Health and Human Services, EPAs,
3. Extent to which collection and transport methods              Local Government Associations and Departments of
affect classification of sharps and RSCs (e.g.,                  Environment, Social Services Commission etc.
Dangerous Goods, Clinical and Sharps Waste and
Special Waste) and resulting transport, storage and              7. Support the Business Case with a high-level financial
management costs.                                                assessment that scopes out the cost / benefit analysis
                                                                 and return on investment period for RSCs versus DSCs.
4. Opportunities for further reuse and recycling
initiatives, including of the sharps themselves.                 8. Scope and map current home RSC disposal options
                                                                 for specific and strategic geographical locations
5. Benchmarking and verified public reporting to                 identified by key stakeholders.
provide transparency and increase government and
public trust in the sector.                                      9. Develop an RSC marketing and communications
                                                                 plan to support the Business Case and test the
                                                                 marcomm plan with key stakeholders in specific and
                                                                 strategic geographical locations e.g. pharmacies,
                                                                 medical centres and doctors’ surgeries.

  8      Stewardship for Reusable Sharps Containers – Business Case Considerations
CONCLUSIONS

This report, building upon previous GlobalPSC                     This report has demonstrated that expanding the use
research, highlights the key considerations for                   of RSCs into home healthcare would be consistent
reusable sharps stewardship. Compared to DSCs,                    with circular economy models and sustainability
RSCs provide a viable option to tackle several of the             principles. Indeed, with an ever-increasing importance
main challenges facing medical waste in the home                  on environmentally friendly practices and as carbon
setting today, while integrating product stewardship              budgets tighten with the effects of climate change
and EPR approaches for producers.                                 becoming more obvious, mass incineration of sharps
                                                                  waste will likely no longer be acceptable.
As redesign, reuse and recycling are not yet viable
options for sharps themselves, an innovative                      A shift towards reuse and recycling will be of greater
approach to the challenge of sharps waste is                      importance. On the back of the COVID-19 pandemic,
needed and regulatory frameworks, including                       and with the move towards increasingly remote
product stewardship and EPR programs, should                      patient care and its associated challenges, the use
allow for flexibility to meet the safety, storage and             of RSCs in the home setting can become part of the
sustainability needs in the home healthcare sharps                solution.
domain.

  9      Stewardship for Reusable Sharps Containers
                                               Stewardship
                                                    – Business
                                                            forCase
                                                                Reusable
                                                                    Considerations
                                                                         Sharps Containers – Business Case Considerations   9
REFERENCES

1.   European Commission 2015, Closing the loop - An EU action plan
     for the Circular Economy. Available at https://eur-lex.europa.eu/
     legal-content/EN/TXT/?uri=CELEX:52015DC0614, accessed April
     2020.

2. GlobalPSC 2016, Product Stewardship for Sharps and Unwanted
   Medicines – Background and Issues Paper.

3. Grimmond 2019, Reusable Sharps Containers: Safety, Sustainability
   and Standards. Presented at International Stewardship Forum,
   Paris, 2 July 2019.

4. McPherson B, Sharip M, Grimmond T; The impact on life cycle
   carbon footprint of converting from disposable to reusable sharps
   containers in a large US hospital geographically distant from
   manufacturing and processing facilities. PeerJ. 2019.

5. OECD 2014, The State of Play on Extended Producer
   Responsibility (EPR): Opportunities and Challenges, available at
   https://www.oecd.org/environment/waste/Global%20Forum%20
   Tokyo%20Issues%20Paper%2030-5-2014.pdf, accessed October
   2020.

6. OECD 2016, Extended Producer Responsibility – Updated
   Guidance for Efficient Waste Management.

7. Republic of France 2018, Roadmap for the Circular Economy.

8. UNPRI 2020, What is the Inevitable Policy Response?, available
   at https://www.unpri.org/what-is-the-inevitable-policy-
   response/4787.article, accessed October 2020.

9. WHO 2016, Global Report on Diabetes, available at https://www.
   who.int/diabetes/global-report/en/, accessed April 2020.

     10     Stewardship for Reusable Sharps Containers – Business Case Considerations
11   Stewardship for Reusable Sharps Containers – Business Case Considerations
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