[h2e] RE: [Pharmwaste] RE: any legislation/ordinancesbanningd isposal of pharmaceuticals to sanitary

Tue Jan 24 16:14:02 EST 2006

Here's a local perspective.  In King County, Washington which includes
Seattle, wastewater goes to two large publicly owned treatment works that
each handle over 100,000,000 gallons a day of raw sewage.

We only fully permit businesses that are categorical industries listed in
the Clean Water Act's pretreatment program specifications described below or
sites that discharge very large volumes of industrial waste water.  All
hospitals in our area are covered by a county-level "blanket discharge
authorization" which allows them to avoid paying much lower fees than for
formal pretreatment permits and limits the frequency of inspections as long
as they follow listed guidelines.  There are two main requirements:

- No discharge of wastewaters that are prohibited from discharge

- No discharge of wastewaters that do not meet the criteria listed in the
Laboratory Waste Management Guidelines

Chemicals, including pharmaceuticals, that designate as federal or
Washington State-only hazardous wastes are not to be disposed to the
sanitary sewer without written permission from our local authority.  We have
not yet fully developed practical collection and transportation methods to
get pharmaceuticals that designate as hazardous waste to waste disposal
incinerators that can process pharmaceutical wastes.  Therefore, we are not
enforcing this restriction, though we probably will at some point in the
next year or two.

We strongly encourage hospitals and clinics to use the Pharmaceutical
Returns Industry for collection and processing of unused no-longer-needed
pharmaceuticals in lieu of disposal. As regulators, we need to acknowledge
that medical professionals are stuck with controlled substances that they
are used to disposing immediately (down the drain).  Some places keep
controlled substances wastes locked up until their reverse distributor takes
it.  For more information on this process, I recommend looking at our
brochure listing screened reverse distributors (they know what RCRA is) at
http://www.govlink.org/hazwaste/publications/0509revDISTROhhw.pdf
<http://www.govlink.org/hazwaste/publications/0509revDISTROhhw.pdf>   You
can also visit the Returns Industry Association's website at
www.returnsindustry.com <http://www.returnsindustry.com>  for more insight
into their industry. 

We currently have a working group from multiple agencies in the process of
developing ways to manage pharmaceutical and controlled substances from
residents and businesses that is efficient and effective for generators of
these wastes.

Dave Waddell, Lead Environmental Investigator

Chair, Medical Industry Waste Prevention Roundtable

Local Hazardous Waste Management Program in King County

206-263-3069  fax 263-3070

-----Original Message-----

From: Gilliam, Allen [mailto:GILLIAM at adeq.state.ar.us] 

Sent: Tuesday, January 24, 2006 7:59 AM

To: H2E - Hospitals for a Healthy Environment - Info Exchange Listserv

Cc: pharmwaste at lists.dep.state.fl.us

Subject: [h2e] RE: [Pharmwaste] RE: any
legislation/ordinancesbanningdisposal of pharmaceuticals to sanitary

H2E -- Hospitals for A Healthy Environment Info Exchange Listserve

(h2e at email.sparklist.com)

No ramblings there Ross!  You're "on the button"!!!  Especially your items
#1 below.

To further confuse/clarify for the non-regulators out there, the state of
Connecticut IS "the city" as their STATE pretreatment program [40 cfr
403.10{e}] regulates (as deemed appropriate) indirect, non-domestic
dischargers FOR their state's publicly owned w.w. treatment systems.  There
are 4 other states in the union that have chosen this "proxy" method of
implementing/enforcing the CWA's pretreatment requirements.

Most all other (~40?) states (that EPA's delegated the CWA's National
Pollutant Discharge Elimination [key word here] System [NPDES]) have chosen
to delegate implementation of the pretreatment program requirements directly
down to their cities' level.  

Clear as filter press sqweezins now?

I know there's other state pretreatment coordinators AND some EPA HQ's folks
following these listserves and am confused by their silence.... 

Allen g 

-----Original Message-----

From: Ross Bunnell [mailto:ross.bunnell at po.state.ct.us] 

Sent: Tuesday, January 24, 2006 9:20 AM

To: Gilliam, Allen; h2e at email.sparklist.com; gressitt at uninets.net

Cc: pharmwaste at lists.dep.state.fl.us

Subject: [Pharmwaste] RE: [h2e] RE: any
legislation/ordinancesbanningdisposal of pharmaceuticals to sanitary

To all:

Pardon me for this response being somewhat off-target for the original
question, which focused on a municipal ordinance, but I think it is relevant
to the overall discussion on the Pharmwaste listserve.

Here at the Connecticut DEP, the staff that have been primarily involved in
the Pharmaceutical waste issue thus far have been our waste program and our
P2 staff.  CT DEP's water staff have thus far had only limited involvement.
And, when we invited Charlotte Smith of PharmEcology to speak to the
Department a few months ago, is was emminently clear that the majority of
our water program staff (and by that I mean the NPDES and Pretreatment
program inspection, enforcement, and permitting staff) were almost
completely unaware of the issue.  Some were surprised (and shocked) that it
was standard practice for some medical care facilities to dump
pharmaceuticals down the drain, and indicated the following:

(1) under Connecticut's incorporation of the federal Clean Water Act
programs, this dispsoal would not be allowed, under the principal that ony
wastewaters (and not concentrated wastes) may be discharged to the sewer;
and,

(2) the discharge of pharmaceutical wastewaters to the sewer would most
likely require a state pretreatment discharge permit.  This permit could be
in the form of a site-specific, individual permit, or a state-wide "general"
permit for this specific discharge at any location in the state that
discharges it, registers for the general permit, and meets the terms and
conditions of the general permit.

Being a waste program person, I don't know if this interpretation is unique
to CT or can be adopted by any state that is authorized to operate the Clean
Water Act pretreatment requirements in lieu of EPA.  Nevertheless, my
experiences with our water staff has led me to a number of conclusions,
namely:

(1)  The water permitting and enforcement staff (in CT at least), have not
fully gotten their arms around this issue yet, and are somewhat further
behind on the learning curve than the waste and P2 flolks.

(2)  It seems to me, having monitored the Pharmwaste listserve for some time
now, that there appears to be an under-representation by water permitting
and enforcement types on the listserve, and that we may wish to reach out to
them and more aggressively engage them in the dialogue.

(3)  The Clean Water Act programs (especially the pretreatment rules) could
provide an excellent vehicle for addressing the drain disposal issue, at
least at non-residential sites (e.g., health care provider facilities),
where most of the "bulk" drain disposal occurs (if not the overall greatest
volume of such disposal, which I have to suspect, would remain households
(it seems to me that local collection events, and not necessarily a sewer
ban, are the most effective way to deal with the household material)).

(4)  The obvious conflict between the Clean Water Act requirements and DEA
requirements for the disposal of controlled substances is clear under this
analysis, and screams for resolution at the federal level (i.e., between EPA
and DEA).

Just my thoughts.  Sorry for rambling.

>>> "Stevan Gressitt" <gressitt at uninets.net> 01/23/06 10:39PM >>>

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  

     -----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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