[Pharmwaste] Hazardous Waste Exports

[gressitt at uninets.net]

A question has arisen within the historical context of the
tons of unusable medical donations that were made to
Bosnia. 3-4 million dollars were need for the incineration
through purchase of new incinerators. The incinerators were
duly purchased and the problem resolved, in part via the
development of more promotional material for the WHO Drug
Donation Guidelines.

What is the argument against the following: 

1) Individual household medicines are generally not
considered hazardous in the US. 

2) Consolidation of more than 1 household ( 2 or more)
moves this into the world of "consolidators" and RCRA as
well as 56 jurisdictions across the country weigh in or not
with further restrictions.

3) As a secondary and simultaneous development DEA
regulations become engaged at point 2 above regarding any
controlled substances.

4) Where classified as hazardous waste by the relevant
jurisdiction, the material now likewise falls u nder the
Berne Convention banning export of hazardous waste.

5) Regulations already exist therefore to ban the practice
of collecting unused medication and dumping it overseas as
in Bandah Aceh where 345 tons now await destruction. The
enforcemetn agencies would be: DEA to control export of
controlled substances, EPA to identify Berne convention
violations (?), and Homeland Security ( Customs and
Immigration) to impound Berne Convention violating
shipments.


I am vague at the point in 5 above where I am not sure
where EPA fits and have put a question mark. The string of
points above however is what I am trying to respond to from
a United States-centric position ( no I'm not defending,
just trying to work out where there may be some options for
adjustment in policy.) 

And oplease I'd rather have some serious obvious criticisms
now than later. Private response is understandable as well.

Stevan Gressitt, M.D.
207-441-0291
gressitt at uninets.net