[Pharmwaste] RE: [h2e] RE: any legislation/ordinances banning disposal of pharmaceuticals to sanitary sewer?

Tue Nov 22 14:25:00 EST 2005

tough questions Dan!

easy, but time and resource intensive anwer?  City Pretreatment programs and their inspectors (doubt the epa will come up with the regs).  40 cfr 403 (the national pretreatment regs which are self-implementing) apply to all "non-domestic dischargers":  

§ 403.2 Objectives of general pretreatment regulations.

By establishing the responsibilities of government and industry to implement National Pretreatment Standards this regulation fulfills three objectives:

(a) To prevent the introduction of pollutants into POTWs [publicly owned treatment works] which will interfere with the operation of a POTW, including interference with its use or disposal of municipal sludge;  

(b) To prevent the introduction of pollutants into POTWs which will pass through [cause toxicity] the treatment works or otherwise be incompatible with such works; and

(c) To improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges.

best management practices or general permits can and might be required, paperwork (daily procedure logs, manifests and/or bills of laden) will have to be available for review upon request by the city's inspectors that all meds/lab chems were disposed of off-site.  these cities have the authority for implementing the same type enforcement options that epa and the states do including civil and/or criminal penalties, administrative orders, severing your sewer service, imprisonment, publishing your facility's name in the local newspaper for being non-compliant, etc.  

that's why the clean water act created the program.  let the cities decide at their own discretion, what's allowed into their sewage collection systems.  who better to make the judgement than the folks protecting its publicly own assets and have a chance to interact with their next door neighbors, business leaders, civic clubs, council members, etc on a daily basis?

it's in this office's lowly opinion that a federal or state decision would side with the city.  if you get down to the Act's Pretreatment reg. bare bones, a city with a publicly owned sewer systerm is not obligated to take ANY non-domestic wastewater.

inducements/incentives?  environmental stewardhip and doing the right thing is a hard sell when there's no immediate monetary gains mentioned in the same sentence (and, as previously mentioned, no absolute proof of toxicity after it passes thru a city's w.w. treatment plant).  avoiding fines would be my reward and a plaque in the window an article in your newletters/ads that your facility is a recognized environmental friendly facility with a certified EMS (go H2E!) should help your bottom line in the long run. 

[sorry, but i've taken the liberty of cc'ing the pharmawaste listserve at the risk of violating any unknown cross talking policies as i know many of you are on both anyway.  somebody chew me out if i did bad....got my leather on today....].

alot of eyes still need to be opened and more information gained nationwide.

have a great holiday,

allen gilliam
adeq state pretreatment coordinator
501.682.0625  

     -----Original Message-----
From: Dan Durett [mailto:durett at verizon.net] 
Sent: Monday, November 07, 2005 10:16 PM
To: H2E - Hospitals for a Healthy Environment - Info Exchange Listserv
Cc: h2e at email.sparklist.com
Subject: [h2e] RE: any legislation/ordinances banning disposal of pharmaceuticals to sanitary sewer?
H2E -- Hospitals for A Healthy Environment Info Exchange Listserve
(h2e at email.sparklist.com)
Banning the disposal of all pharmaceuticals to the sanitary sewer through an ordinance will accomplish what level of reduction?  What time frame?  How will the ordinance be implemented and monitored?  What enforcement model will be utilized (penalty of fines, impreisonmet or both?)  What inducements / incentives will be in place? Will there be awards relating to compliance?  How will the ordinance be applied? Will it first be applied to university based research operations and hospitals? To private hospitals and then public ones?  Before adopting an ordinance have they looked at recent state or federal court decisions?  

	Not sure these questions are helpful.  However, IF I was siting on a city council, these are just some of the many questions I would want to have answers to prior to voting yes on this matter.   

	Dan Durett, President

	Dan Durett & Associates

	257 St. Marks Place

	Staten Island, NY 10301

	(B) 718-876-0718

	(F) 718-876-7988

	(C) 347-563-5965

	durett at verizon.net

________________________________

	From: Barr, Marcia [mailto:barrm at upmc.edu] 
	Sent: Monday, November 07, 2005 12:59 PM
	To: H2E - Hospitals for a Healthy Environment - Info Exchange Listserv
	Subject: [h2e] RE: any legislation/ordinances banning disposal of pharmaceuticals to sanitary sewer?

	H2E -- Hospitals for A Healthy Environment Info Exchange Listserve
	(h2e at email.sparklist.com)

	Dave,

	Can you answer this?

	Marcia M. Barr, BSCE 
	Division Director 
	Center for Environmental Oncology 
	Environmental Assessment, Monitoring & Control Division 
	Phone: 412.623.5783 
	Fax: 412.623.3201 
	http://www.upci.upmc.edu/ceo 

		-----Original Message-----
		From: Cecilia Deloach [mailto:cdeloach at hcwh.org]
		Sent: Monday, November 07, 2005 11:53 AM
		To: H2E - Hospitals for a Healthy Environment - Info Exchange Listserv
		Subject: [h2e] any legislation/ordinances banning disposal of pharmaceuticals to sanitary sewer?

		H2E -- Hospitals for A Healthy Environment Info Exchange Listserve
		(h2e at email.sparklist.com)

		Hi all-

		One of the municipalities we are working with is considering an ordinance to ban the disposal of all pharmaceuticals to the sanitary sewer. Does anyone know of any other city, municipality, state or other who has passed a similar ban? I know there is a lot of concern about pharmaceuticals in wastewater, but just trying to get a sense of what regulatory action has been taken on this area.

		Many thanks in advance for your input.

		Cecilia DeLoach

		H2E State Partnership Program Coordinator

		1901 N. Moore Street, Suite 509

		Arlington, VA 22209

		Ph: 800-727-4179

		E-mail: cecilia.deloach at h2e-online.org 

		www.h2e-online.org 

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