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

[Gilliam, Allen]

Ms. Otteni?

was the brief (below) on the CWA's national pretreatment program's objectives what you were looking for back in December?

thanx again to Dr. Gressitt for pointing out other costs that are real but, hard (impossible at this time?) to tabulate.

this has probably already been posted but, see interesting article: Emerging Liabilities from Pharmaceuticals and Personal Care Products @

http://www.howrey.com/docs/liabilitiespharmaceuticals20020401.pdf 

allen g

	-----Original Message-----
	From: Stevan Gressitt [mailto:gressitt at uninets.net] 
	Sent: Monday, January 23, 2006 9:39 PM
	To: Gilliam, Allen; 'H2E - Hospitals for a Healthy Environment - Info Exchange Listserv'
	Cc: pharmwaste at lists.dep.state.fl.us
	Subject: RE: [h2e] RE: any legislation/ordinances banning disposal of pharmaceuticals to sanitary sewer?
	
	

	Apologies for being late in replying but I had been saving this for when I had a few minutes to go over the regs. I'll defer on those for now. 

	 

	At the bottom where you comment on the economics. Could I suggest that the paradigm for costing out the value is missing variables that actually make this a very simple sell.

	 

	1.	Cost of childhood accidental poisonings. 
	2.	Cost of burglary for drugs, and teenage pharming 
	3.	Cost of patient medication errors from having accumulated a confusing pile 
	4.	Cost of environmental injury goes here...someday 

	 

	But there is now a 5th: The cost of disposal in third world countries of badly donated drugs that don't meet the 1999 WHO Guidelines and that now for example have a price tag of over 1 million Euros in Banda Aceh alone for the 340 tons of unusable "donations." 

	 

	Maybe I'm overstating a bit, but those seem compelling arguments and I simply added the word cost to each for the sake of this email.

	 

	Seems actually to make it more starkly important.

	 

	Stevan Gressitt, M.D.

	207-441-0291  

	 

	
________________________________


	From: Gilliam, Allen [mailto:GILLIAM at adeq.state.ar.us] 
	Sent: Tuesday, November 22, 2005 2:25 PM
	To: H2E - Hospitals for a Healthy Environment - Info Exchange Listserv
	Cc: pharmwaste at lists.dep.state.fl.us
	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)

	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  

	 

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