[Pharmwaste] Pharmaceutical Waste

Sat, 15 Jan 2005 14:53:15 -0600

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Dear Listserve:

I would appreciate if someone could provide answer to the following
question.

Simply out of curiosity, I understand the (potential / possible) need t=
o
create a system to deal with this issue, but unlike latex paint,
electronics and carpet, amongst others, it would appear to this uniniti=
ated
person that there is little reclaimable asset to be gained from spent /=
 out
of date pharmaceuticals.

Allowing that there is little benefit, then we have the issue of these =
not
falling into inappropriate hands. At least in the narcotics area.

Pharmaceuticals once issued to the end user are "out of the loop" of th=
e
FDA and would then at end of life become "HHW", and it appears should t=
hen
be treated as any other HHW.

It would appear that these items would simply be best placed amongst ot=
her
"toxics", drummed without external indicative labelling (Eg. NOS, Toxic=
, 6
(6.1)) and shipped for incineration. They would not then require to go =
to
an FDA approved incinerator.

An alternative would be to place in an A fuel drum (all parties in
agreement) and ship in that fashion.

For the amounts and quantities involved in most programs, this would se=
em
the easy solution, for programs specifically chasing these wastestreams=
 as
a revenue source, they could arrange contracts as appropriate under
auspices of the FDA if they themselves saw a need to regulate material
which was regulatorily in the vast majority of cases "de-regulated" by =
age
or condition.

I look forward to the discussion thread this question line may provoke.=

Sincerely.

Bill Lewry / KCMO.=

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<html><body>
Dear Listserve: 
 
I would appreciate if someone could provide answer to the following que=
stion. 
 
Simply out of curiosity, I understand the (potential / possible)=
 need to create a system to deal with this issue, but unlike latex pain=
t, electronics and carpet, amongst others, it would appear to this unin=
itiated person that there is little reclaimable asset to be gained from=
 spent / out of date pharmaceuticals. 
 
Allowing that there is little benefit, then we have the issue of these =
not falling into inappropriate hands. At least in the narcotics area.<b=
r>
 
Pharmaceuticals once issued to the end user are &quot;out of the loop&q=
uot; of the FDA and would then at end of life become &quot;HHW&quot;, a=
nd it appears should then be treated as any other HHW. 
 
It would appear that these items would simply be best placed amongst ot=
her &quot;toxics&quot;, drummed without external indicative labelling (=
Eg. NOS, Toxic, 6 (6.1)) and shipped for incineration. They would not t=
hen require to go to an FDA approved incinerator. 
 
An alternative would be to place in an A fuel drum (all parties in agre=
ement) and ship in that fashion. 
 
For the amounts and quantities involved in most programs, this would se=
em the easy solution, for programs specifically chasing these wastestre=
ams as a revenue source, they could arrange contracts as appropriate un=
der auspices of the FDA if they themselves saw a need to regulate mater=
ial which was regulatorily in the vast majority of cases &quot;de-regul=
ated&quot; by age or condition. 
 
I look forward to the discussion thread this question line may provoke.=
 
 
Sincerely. 
 
Bill Lewry / KCMO.</body></html>=

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