Surprisingly, few clinical waste treatment facilities maintain radiation monitors and alarm systems. Limited largely to incinerator feed systems – who wants a cloud of radioactive particles released to atmosphere? – it is perhaps surprising that these have not been required also for ATT facilities.

With the rise of nuclear medicine that involves the administration of potent radioactive drug preparations, usually for the treatment of cancers, or the administration of smaller doses for a wide range of diagnostic procedures, this seems to be a ‘problem’ that has slipped under the radar of regulation.

The amount of radiation may be modest when used for diagnostic procedures but patients may remain “hot” for a day or two and are advised to stay clear of young children and pregnant women. So, there is a risk, but perhaps only a small risk and care in disposal of wastes, mainly faeces and urine is considered not to be a problem. Massive dilution into the sewage system and natural radioactive decay of radiopharmaceuticals having short half-lives is considered sufficient.

There is a possibility, as yet untested, that autoclave processing of wastes will liberate some part of any radiopharmaceutical to atmosphere or autoclave wastewater. This is not likely to result from patient materials but perhaps from the paraphernalia of drug administration in circumstances where, perhaps improperly, these have not been separately bagged and held securely until radioactive decay has occurred and the wastes released, all under the supervision of a suitably qualified radiation officer.

At least one US city waste collection service has been troubled by radioactive waste, of domiciliary  origin, though surely this is an exception. http://enewscourier.com/local/x1614272818/Medical-waste-affects-citys-garbage-pickup

With good standards of radiation safety in hospitals, this should never be a problem. It is more apparent than real, and a reasoned approach to regulation, taking account of half life and quantity and expecting that decay will occur rapidly, should suffice. Proportionality is the key, assuming that nobody is likely to dump the year’s supply into an orange waste sack and walk away from it!

But why do these small traces of radioactive pharmaceuticals likely to arise also from university and commercial research labs, escape regulatory oversight. We should be reassured that without heavy regulation there really is no unseen problem, but this should be set against the sometimes excessive concerns regarding a few tablets found in the bottom of a waste sack, a discarded blister pack, or an empty syringe in a sharps bin, that are expected to contain sufficient pharmaceutical residues to place the environment at great risk. This precipitates demands, sometimes without a clear legal framework in support but instead the result of being ‘leant on’ but someone setting out on a fishing exercise or simply having a bee in their bonnet and feeling able to fly alone irrespective of the regulations to which both regulators and operators are obliged to comply!

Once again, proportionality is the key. If regulatory concerns regarding one are necessary then so might the other, but if one can be discounted then so too might the other. This should lead to relaxation of the sometimes petty demands of meaningless “research” assessments regarding drug residues in waste processing residues imposed, generally without a clear legal foundation, in the run-up to award of a waste permit.

But can proportionality overcome regulatory belligerence and a palpable failure to apply sound scientific reasoning?