[Pharmwaste] Question regarding incinerators
gressitt at uninets.net
gressitt at uninets.net
Thu Feb 1 11:46:55 EST 2007
And they would not fall under state reguilatory guidance? What If say I
offered to get one of those contraptions and drove around the neiborhood
burning up only single family hazardous chemicals? no consolidation of any
kind. What then? Stevan Gressitt, M.D.
>
> Stevan: The interesting question you raise - "how can they sell these
> things"
>
> Simple answer - the supreme court.
>
> In the 1800's there was a justice who did EVERYTHING pro industry &
> private
> property (see - history of the supreme court - PBS.) with the result that
> we still live with many of these issues today. It is vital to remember
> there is effectively NO GOVERNMENTAL CONSUMER PROTECTION IN THE UNITED
> STATES. (If there were - chem manufacturers and perfumers would be held to
> prove their materials safe BEFORE the lawsuits for damages and destroyed
> lives).
>
> One of those issues is that it's legal to manufacture and sell almost
> anything not specifically proscribed until one of 3 things happen.
>
> You can't sell enough, or generate enough money from sales, so you go
> broke.
> Government specifically enacts a law preventing you.
> You get sued so often for a faulty product - you go live in the Bahamas
> from your ill gotten gains.
>
> So - they can design, manufacture and sell - but it's up to you to figure
> out if it's legal to use.......................
>
>
>
> "gressitt"
> <gressitt at uninets
> .net> To
> "'Volkman, Jennifer'"
> 01/31/2007 06:35 <Jennifer.Volkman at state.mn.us>,
> PM "'Bill Lewry'"
> <Bill_Lewry at kcmo.org>
> cc
> <pickrel.jan at epamail.epa.gov>,
> "'Vizzier, Michael'"
> <michael.vizzier at sdcounty.ca.gov>,
> <kcrecycling at earthlink.net>,
> "'Matthew Mireles'"
> <mirelesmc at earthlink.net>
> Subject
> RE: [Pharmwaste] Question regarding
> incinerators
>
>
>
>
>
>
>
>
>
>
> Wait a minute. That is my business plan. I'm going to get a bright shiny
> new
> F-150 pick up truck, put that Terminator in the back and go from police
> station to police station ( and anywhere else that will pay the lighter
> fee
> like say summer fairs?) and take care of the problem. Course if you're
> downwind and get a little too much pentobarbital.... I'm wondering how
> does
> Prozac flavored barbecue sound?
>
> And that is one of the questions I have. Why can they sell these things?
> Aren't there environmental regulations you folks would bring up? Sounds
> like
> they are selling pretty much all over the country and rather under the
> radar
> too. Journalist out there?
> Stevan
>
>
> -----Original Message-----
> From: Volkman, Jennifer [mailto:Jennifer.Volkman at state.mn.us]
> Sent: Wednesday, January 31, 2007 4:39 PM
> To: gressitt at uninets.net; Bill Lewry
> Cc: Volkman, Jennifer; pickrel.jan at epamail.epa.gov; Vizzier, Michael;
> kcrecycling at earthlink.net; Matthew Mireles
> Subject: RE: [Pharmwaste] Question regarding incinerators
>
> I'm going to open a dealership instead. Bill, I'm telling your
> contractor that you can't do what you're doing. How many do you want?
>
> -----Original Message-----
> From: gressitt at uninets.net [mailto:gressitt at uninets.net]
> Sent: Wednesday, January 31, 2007 1:07 PM
> To: Bill Lewry
> Cc: Volkman, Jennifer; pickrel.jan at epamail.epa.gov; Vizzier, Michael;
> kcrecycling at earthlink.net; Matthew Mireles
> Subject: RE: [Pharmwaste] Question regarding incinerators
>
>
> But I'll bet neither of you own stock in www.drugterminator.com Nor
> have
> your departments "authorized" a perfect gas dispersal device that gives
> some security types the willies... Grin. Stevan
>
>>
>> This is how we perform a witnessed destruction of narcotics in KC.
>>
>> WE 1/2 fill a 55 gallon drum with an A fuel blend then follow what Jen
>
>> has stated below.
>>
>> Drum then goes out for incineration, in the case of non-controlled - A
>
>> fuel.
>>
>>
>>
>> "Volkman,
>> Jennifer"
>> <Jennifer.Volkman
> To
>> @state.mn.us> <kcrecycling at earthlink.net>,
>> Sent by: "Jennifer Volkman"
>> pharmwaste-bounce <Jennifer.Volkman at state.mn.us>,
>> s at lists.dep.state <Pickrel.Jan at epamail.epa.gov>,
>> .fl.us "Matthew Mireles"
>> <mirelesmc at earthlink.net>
>>
> cc
>> 01/30/2007 01:48 "Vizzier, Michael"
>> PM
> <Michael.Vizzier at sdcounty.ca.gov>,
>>
> pharmwaste at lists.dep.state.fl.us
>>
> Subject
>> RE: [Pharmwaste] Question
> regarding
>> incinerators
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>> I don't think legalities related to controlled substances are an issue
>
>> when the drugs are considered "destroyed" or non-usable for their
>> intended purpose. We could get a read from DEA on that. Some other
>> issues that I can think of are:
>>
>> 1)HH have to follow directions: combine, mash, mix with vinegar, peel
>> labels;
>>
>> 2)I posed the idea as mixing all meds together, and adding vinegar (or
>
>> whatever anyone else thinks would work--it's cheap and nasty). In
>> that scenario HH would not necessarily bring in waste in original
>> containers, which we harp on for all other waste streams, so there is
>> an inconsistency there (but it is also an opportunity to re-emphasize
>> that for all other waste streams). Or we could ask them to add
>> vinegar, etc. to each bottle and not mix them together. This wouldn't
>
>> be much of a problem if you had a couple of bottles, but would get
>> very tedious for a larger cleanout;
>>
>> 3)Some drugs, like chemo, might need to be kept separate for waste
>> categorization and management reasons, but I think most all can go as
>> lab pack poisons for incineration--someone help me out on this one, I
>> don't pack waste. If we can go with one labpack category, this could
>> be very simple. I also don't know of any incompatibility issues.
>> Since it is all consummable there shouldn't be any.
>>
>> 4) Collection of data on waste meds would be dependent on whether HH
>> will provide info separately since tablets will be destroyed, liquid
>> quantities would be greater and many meds might be mixed together.
>> Labels on my Rx bottles come off real easily, so I think sticking them
>
>> on a piece of paper with an estimated count/quantity is simple, but
>> others won't want to bother.
>>
>> If we can clarify #3, we should be good to go. #1 is only of mild
>> interest because there will be no way to tell if the nasty mix is or
>> is not a controlled substance and it shouldn't matter if it was.
>>
>> Thanks,
>> Jnifr
>> -----Original Message-----
>> From: kcrecycling at earthlink.net [mailto:kcrecycling at earthlink.net]
>> Sent: Tuesday, January 30, 2007 12:33 PM
>> To: Jennifer Volkman; Pickrel.Jan at epamail.epa.gov; Matthew Mireles
>> Cc: Vizzier, Michael; pharmwaste at lists.dep.state.fl.us
>> Subject: RE: [Pharmwaste] Question regarding incinerators
>>
>>
>> I like your idea Jennifer! It could simplify the collection
>> process---no need for a deputy officer to take the "controlled
>> stuff"---but how do the legalities play out?
>>
>>
>> kcrecycling at earthlink.net
>> EarthLink Revolves Around You.
>> Sue Studebaker, Director
>>
>>
>>> [Original Message]
>>> From: Volkman, Jennifer <Jennifer.Volkman at state.mn.us>
>>> To: <Pickrel.Jan at epamail.epa.gov>; Matthew Mireles
>> <mirelesmc at earthlink.net>
>>> Cc: Vizzier, Michael <Michael.Vizzier at sdcounty.ca.gov>;
>> <pharmwaste at lists.dep.state.fl.us>
>>> Date: 1/29/2007 4:36:38 PM
>>> Subject: RE: [Pharmwaste] Question regarding incinerators
>>>
>>> OK, another thought on this, maybe it has been thrown out already
>>> somewhere in the past and eliminated for reasons that I can probably
>>> come up with on my own... :)
>>>
>>> How about if we have patients rip off all labels, mix all their pills
>
>>> and liquids together with vinegar and bring/mail them in for
>>> collection. The meds are effectively destroyed/unidentifiable so DEA
>>> won't be excited. The collectors ship them to a HW incinerator in
>>> lab
>>
>>> packs labeled as D001/poisons/pesticides, or the most appropriate DOT
>
>>> hazard class for the mixture.
>>>
>>> Participants can stick the labels with their name/number blacked out
>>> to a sheet of paper with an estimation on the count/quantity for each
>
>>> if the collector would like to share that info with a program like
>>> the
>>
>>> Unused and Expired Medicines Registry.
>>>
>>> If we make it simple enough for collectors, maybe more will do it.
>>>
>>> -----Original Message-----
>>> From: pharmwaste-bounces at lists.dep.state.fl.us
>>> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
>>> Pickrel.Jan at epamail.epa.gov
>>> Sent: Friday, January 26, 2007 11:13 AM
>>> To: Matthew Mireles
>>> Cc: 'Vizzier, Michael'; pharmwaste at lists.dep.state.fl.us
>>> Subject: RE: [Pharmwaste] Question regarding incinerators
>>>
>>>
>>> "Characteristic" hazardous waste is any wastes that fall into the
>>> following categories (see 40 CFR 261, Subpart C): Ignitability is 40
>>> CFR 261.21; Corrosivity is 40 CFR 261.22; Reactivity is 40 CFR
>>> 261.23;
>>
>>> Toxicity is 40 CFR 261.24.
>>>
>>> If you are pouring something down a sink that ultimately makes its
>>> way
>>
>>> to a publicly owned treatment works, please also read the
>>> Pretreatment
>>
>>> Regulations specific and general prohibitions at 40 CFR 403.5. There
>>> is also a special reporting condition in the Pretreatment regulations
>
>>> regarding hazardous wastes in 40 CFR 403.12(p).
>>> ~*^*~*^*~*^*~*^*~*^*~*^*~ Jan Pickrel
>>>
>>>
>>>
>>
>>> Matthew Mireles
>>
>>> <mirelesmc at earth
>>
>>> link.net>
>> To
>>> "'Vizzier, Michael'"
>>
>>> 01/26/2007 11:56
>> <Michael.Vizzier at sdcounty.ca.gov>
>>> AM , Jan Pickrel/DC/USEPA/US at EPA,
>>
>>>
>>> pharmwaste at lists.dep.state.fl.us
>>
>>>
>>> cc
>>>
>>
>>>
>> Subject
>>> RE: [Pharmwaste] Question
>>
>>> regarding incinerators
>>
>>>
>>
>>>
>>
>>>
>>
>>>
>>
>>>
>>
>>>
>>
>>>
>>>
>>>
>>>
>>> Good point. I haven't heard of D001 and imagine it would apply to
>>> mostly anesthetic agents (a little more effective than gin). My
>>> background is biomedical engineering and I still remember the
>>> dreadful
>>
>>> assignment of pouring unused jars of agents down the sink weekly.
>>>
>>> Matthew Mireles
>>>
>>> -----Original Message-----
>>> From: pharmwaste-bounces at lists.dep.state.fl.us
>>> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
>>> Vizzier, Michael
>>> Sent: Friday, January 26, 2007 10:07 AM
>>> To: Pickrel.Jan at epamail.epa.gov; pharmwaste at lists.dep.state.fl.us
>>> Subject: RE: [Pharmwaste] Question regarding incinerators
>>>
>>> Another category of RCRA waste that sometimes captures
>>> pharmaceuticals
>>
>>> is D001. D001 wastes exhibit the characteristic of ignitibility,
>>> which is defined as liquids with a flash point less than 140 F,
>>> excluding aqueous solutions containing less than 24% alcohol - an
>>> exemption for gin & tonic.
>>>
>>> Michael Vizzier
>>> County of San Diego
>>> Hazardous Materials Division
>>> (858) 495-5672
>>> -----Original Message-----
>>> From: pharmwaste-bounces at lists.dep.state.fl.us
>>> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
>>> Pickrel.Jan at epamail.epa.gov
>>> Sent: Friday, January 26, 2007 7:11 AM
>>> To: pharmwaste at lists.dep.state.fl.us
>>> Subject: RE: [Pharmwaste] Question regarding incinerators
>>>
>>> See P-listed and U-listed wastes at 40 CFR 261.33.
>>> - -Jan
>>> ~*^*~*^*~*^*~*^*~*^*~*^*~
>>> Jan Pickrel
>>> Water Permits Division, Industrial Branch
>>> US Environmental Protection Agency
>>> phone: (202) 564-7904.
>>> fax: (202) 564-6431.
>>> pickrel.jan at epa.gov
>>>
>>>
>>>
>>>
>>> Matthew Mireles
>>> <mirelesmc at earth
>>> link.net>
>> To
>>> Sent by: "'Taam, Damon'"
>>> pharmwaste-bounc <DTaam at spokanecity.org>,
>>> es at lists.dep.sta
>> pharmwaste-bounces at lists.dep.stat
>>> te.fl.us e.fl.us,
>>>
>>> pharmwaste at lists.dep.state.fl.us
>>>
>> cc
>>> 01/26/2007 09:30 cecilia.deloach at h2e-online.org,
>>> AM rachel.golden at ncmail.net,
>>> 'Elizabeth Smith'
>>> <smithce at flash.net>, 'Mary
>>> Kohrell'
>>>
> <kohrell.mary at co.calumet.wi.us>,
>>> 'Racheal Johnson'
>>> <rjohnson1 at sleh.com>,
> "'Hampton,
>>> Anita F'"
>>> <Anita.F.Hampton at nhmccd.edu>
>>>
>> Subject
>>> RE: [Pharmwaste] Question
>>> regarding incinerators
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> Damon,
>>> Thanks for wealth of information you provided on this thread. Can
>>> you
>>
>>> point to me specific RCRA references regarding pharmaceutical items
>>> being classified as both or either hazardous waster and/or solid
>>> waste? I have been searching for these references and have not found
>> any
>>> determination on general classification specific to pharmaceuticals.
>> I
>>> conclude that in practice we don't group pharmaceuticals with
>>> "medical
>>
>>> waste", and I'm not sure if there's a uniform acceptance of grouping
>>> them as hazardous waste or solid waste, except perhaps certain items,
>
>>> such as antineoplastics and radioactive therapeutic agents. Would
>>> RCRA address both prescripts and OTC? When do drugs become hazardous
>
>>> waste, after expiry date, when no longer used by patients/consumer,
>>> when they appear in trash cans or landfill?
>>>
>>> Our Foundation has been collecting data on returned drugs from
>>> various
>>
>>> collection events throughout the country. Any info you can provide,
>>> specifically concerning RCRA references, would be helpful. So far,
>>> we
>>
>>> have coded nearly 5,000 items, mainly to get a snapshot of the types
>>> of drugs, quantity (actual pill count) returned, reason why they are
>>> returned. We also code average wholesale price, environmental hazard
>
>>> potential (based on the Swedish database: persistence,
>>> bioaccumulation, and toxicity), as well as potential occupational
>>> hazard exposure. Workers at solid waste treatment facilities probably
>
>>> are exposed to some level. Both DEA and EPA are not specific to
>>> occupational exposure, and the RCRA cites I discovered mention the
>>> authority and responsibility of OSHA in this matter.
>>>
>>> I agree with you that this problem extremely complex. Your
>>> contribution to our discussion and the elucidation of just the basic
>>> classification of pharmaceutical and personal care products as
>>> hazardous waste and/or solid waste are both helpful and intriguing.
>>> I'm sure others will have additional comments.
>>>
>>>
>>> Matthew C. Mireles, Ph.D., M.P.H.
>>> President and CEO
>>> Community Medical Foundation for Patient Safety
>>> 6800 West Loop South, Suite 190
>>> Bellaire, Texas 77401
>>> Phone and fax: 832-778-7777
>>> www.communityofcompetence.com
>>> cc
>>>
>>>
>>> From: pharmwaste-bounces at lists.dep.state.fl.us
>>> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Taam,
>>> Damon
>>> Sent: Thursday, January 25, 2007 7:45 PM
>>> To: pharmwaste-bounces at lists.dep.state.fl.us;
>>> pharmwaste at lists.dep.state.fl.us
>>> Cc: rachel.golden at ncmail.net; cecilia.deloach at h2e-online.org
>>> Subject: RE: [Pharmwaste] Question regarding incinerators
>>>
>>> HI all;
>>>
>>> RCRA is the federal law that manages waste. It is divided into two
>>> categories: Hazardous waste (Subtitle C) and Solid Waste/garbage
>>> (Subtitle D). Pharmaceuticals fall into both categories, each of
>>> these
>>
>>> categories have very specific regulations to follow. Managing the
>>> disposal of a hazardous waste is very costly, fortunately most
>>> pharmaceuticals fall into the solid waste classification. If the
>>> wastes comes from a household they are exempt from the hazardous
>>> waste
>>
>>> regulations and therefore are classified as a solid wastes. Some
>>> States like WA and CA also have their own hazardous waste laws that
>>> are more stringent than the federal rules and need to be complied
>>> with. Pharmaceutical wastes are typically divided into three
>>> categories: Controlled substances, Legend drug, and Over the counter
>>> drugs. Controlled substances are regulated by the DEA. The DEA has
>>> very specific rules which need to be complied with, and the penalties
>
>>> for non-compliance are steep and serious. Currently, the DEA does not
>
>>> allow anyone other than the prescribed patient, a DEA licensed
>>> company(reverse
>>> distributor) and law enforcement entity manage controlled substances.
>
>>> The EPA is also serious about how and who manages hazardous waste.
>>> The problem is that DEA requires controlled substances to be
>>> destroyed and made unusable (to avoid reuse and abuse of the drug)
>>> via an approved process. Typically, that means incineration in an
>>> approved facility. There are not many facilities that are DEA & EPA
>>> approved for the disposal of controlled substances and hazardous
>>> waste. Most of the DEA approved facilities are like Spokane Waste to
>>> Energy Facility. Our facility is a clean modern Waste to Energy
>>> facility and should not be confused with incinerators of the past.
>>> They are built with sophisticated combustion and air pollution
>>> controls systems. Both
>> dioxin
>>> and mercury are controlled and regulated to levels that are minimal
>> and
>>> not a health risk. These facilities are built to destroy organic
>>> waste of which 95% of the pharmaceuticals are. Pharmaceuticals in WA
>>> are not regulated as a Dangerous Waste(State Hazardous) as long as
>>> they are disposed of in facilities such as Spokane's. For more
>>> information see our website: www.solidwaste.org Clearly
>>> pharmaceuticals need to destroyed and not discharged into our rivers,
>
>>> lakes and our oceans. Landfills do not destroy the products, they
>>> store them for our future generations to manage. Other technologies
>>> do exist but are
>> developmental
>>> and have yet to commercially prove themselves as effective, reliable
>> and
>>> cost effective. Pharmaceuticals, like garbage isn't homogeneous and
>> can
>>> vary greatly on it's makeup and characteristics, therefore any new
>>> technology will need to address many types of pharmaceuticals.
>>>
>>> Medical waste is an undefined term, but specifically is seen as waste
>
>>> from a medical facility. That in it's self is a wide range of wastes:
>
>>> sharps, paper, body parts, infectious waste, drugs, plastic trays,
>>> etc. Some view it as just infectious waste. Needless to say it is a
>>> label, and needs to be managed properly and not create a potential
>>> problem. Medical waste incinerators of the past do not exist anymore
>>> due to new requirements. They have either been modified with new
>>> technology or just shut down, mostly the later. Compliance with the
>>> new regulation are extensive and therefore are expensive. On the plus
>
>>> side, any existing combustion facilities are very clean, do a much
>>> better job and have less an impact on our environment.
>>>
>>> Hazardous waste incinerators (vs Solid Waste combustors) burn at much
>
>>> higher temperatures but have similar air pollution control devices
>>> and
>>
>>> are licensed and dedicated to destroying hazardous waste. Typically
>>> hazardous waste incinerators utilize a lot of supplemental fuels to
>>> maintain the high temperature destruction environment 4000F+, whereas
>
>>> a municipal Waste to Energy facility will operate in the 2500F range
>>> with supplemental fuel for startup and shutdown only. There are trade
>
>>> offs, higher temperatures guarantee 100% destruction of all
>>> organics(necessary for hazardous waste) but also create an
>>> environment
>>
>>> that generates large quantities of NOX emissions. I hope this helps
>>> you understand the complexity of the problem and the miriad of
>>> regulations that need to be complied with.
>>>
>>>
>>> Damon M.K. Taam
>>> Spokane Regional Solid Waste System
>>> 808 Spokane Falls Blvd.
>>> Spokane, WA 99201
>>>
>>> (509) 625-6580 Office
>>> (509) 625-6537 Fax
>>>
>>> -----Original Message-----
>>> From: [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On
>> Behalf
>>> Of gressitt
>>> Sent: Wednesday, January 24, 2007 5:25 PM
>>> To: 'Cecilia DeLoach'; 'Bill Lewry'; 'Volkman, Jennifer'
>>> Cc: pharmwaste-bounces at lists.dep.state.fl.us;
>>> pharmwaste at lists.dep.state.fl.us; 'rachel golden'
>>> Subject: RE: [Pharmwaste] Question regarding incinerators
>>> I would be interested in the same.
>>> Stevan Gressitt, M.D.
>>> 207-441-0291
>>> www.mainebenzo.org
>>>
>>>
>>>
>>> From: pharmwaste-bounces at lists.dep.state.fl.us
>>> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
>>> Cecilia DeLoach
>>> Sent: Friday, January 19, 2007 12:06 PM
>>> To: 'Bill Lewry'; 'Volkman, Jennifer'
>>> Cc: pharmwaste-bounces at lists.dep.state.fl.us;
>>> pharmwaste at lists.dep.state.fl.us; 'rachel golden'
>>> Subject: RE: [Pharmwaste] Question regarding incinerators
>>>
>>> Hi all-
>>>
>>> I'm wondering if any of you are familiar with other acceptable
>>> treatment technologies for the disposal of non-RCRA
>> pharmaceutical
>>> waste. Many of you are likely familiar with our organization-
>>> Hospitals for a Healthy Environment (H2E). And we are concerned
>>> about a placing a new reliance on medical or municipal waste
>>> incinerators at a time when we are working hard to decrease the
>>> necessity of burning any hospital generated waste (due to
>> concerns
>>> around dioxin generation and mercury emissions in particular).
>>>
>>> Have there been any discussions on this list about other
>> approved
>>> technologies for the destruction of non-RCRA pharm waste? Is
>>> anyone aware of any testing of autoclaves, alkaline hydrolysis,
>>> microwaves or other "treatment technologies" for pharm waste?
>>>
>>> I'd be very interested in hearing from you if so.
>>>
>>> Many thanks,
>>> Cecilia
>>>
>>> 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
>>>
>>> -----Original Message-----
>>> From: pharmwaste-bounces at lists.dep.state.fl.us
>>> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On
>> Behalf
>>> Of Bill Lewry
>>> Sent: Friday, January 19, 2007 11:23 AM
>>> To: Volkman, Jennifer
>>> Cc: pharmwaste-bounces at lists.dep.state.fl.us;
>>> pharmwaste at lists.dep.state.fl.us; rachel golden
>>> Subject: RE: [Pharmwaste] Question regarding incinerators
>>>
>>>
>>>
>>> Rachel:
>>>
>>> Jennifer is absolutely correct here - one additional
>> caveat
>>> - if the medical waste is a controlled substance it must
>> go
>>> to a DEA approved incinerator.
>>> (Embedded image moved to file: pic08324.gif)Inactive hide
>>> details for "Volkman, Jennifer"
>>> <Jennifer.Volkman at state.mn.us>"Volkman, Jennifer"
>>> <Jennifer.Volkman at state.mn.us>
>>>
>>>
>>>
>>> "Volkma
>>> n,
>>> Jennife
>>> r" (Embedded image moved to file:
>>> <Jennif pic27799.gif)
>>> er.Volk
>> To
>>> man at sta (Embedded image moved to
>>> te.mn.u file: pic15653.gif)
>>> s> "rachel golden"
>>> Sent
>> <rachel.golden at ncmail.net>
>>> by: ,
>>> pharmwa
>> <pharmwaste at lists.dep.stat
>>> ste-bou e.fl.us>
>>> nces at li (Embedded image moved to file:
>>> sts.dep pic07701.gif)
>>> .state.
>> cc
>>> fl.us (Embedded image moved to
>>> file: pic28841.gif)
>>> (Embedded image moved to file:
>>> 01/17/2 pic04404.gif)
>>> 007
>> Subject
>>> 03:32 (Embedded image moved to
>>> PM file: pic15729.gif)
>>> RE: [Pharmwaste]
> Question
>>> regharding incinerators
>>>
>>>
>>>
>>>
>>>
>>>
>>> (Embedded image moved to file:
>>> pic19215.gif)
>>> (Embedded image moved
>> to
>>> file: pic30565.gif)
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> Depending on the type of incinerator, how it is fed and
>> the
>>> emission control system, a medical or infectious waste
>>> incinerator might do as good a job destroying pharms as a
>>> haz waste incinerator. Regardless, any pharm waste that
>> is
>>> categorized as a RCRA haz waste must go to a RCRA
>> permitted
>>> haz waste incinerator. If a pharm is not a HW it could
> go
>>> to a medical/infectious waste incinerator if your state
>>> permits that. You should check in with your state or
>> local
>>> HW inspectors.
>>>
>>> ________________________________
>>>
>>> From: pharmwaste-bounces at lists.dep.state.fl.us on behalf
>> of
>>> rachel golden
>>> Sent: Wed 1/17/2007 2:14 PM
>>> To: pharmwaste at lists.dep.state.fl.us
>>> Subject: [Pharmwaste] Question regharding incinerators
>>>
>>>
>>> I have a question regarding the incineration of unused
>>> pharmaceuticals. I am relatively new to the list, so
>>> forgive me if this has been discussed before. I believe
>>> that unused drugs in North Carolina sent through a
> reverse
>>> distributor end up being incinerated at a medical waste
>>> facility. The point was recently made that
>> pharmaceuticals
>>> are considered hazardous waste, not medical waste, and
>> that
>>> the incineration process safe for medical waste is not
>>> necessarily safe for drugs. Does anybody have any
>>> information on this subject from anywhere in the U.S.?
>>> Specifically, what are the differences between
>> incinerators
>>> built to handle medical waste versus hazardous waste?
> Are
>>> drugs considered to be medical waste or hazardous waste?
>>> I appreciate the help!
>>> Rachel
>>>
>>> --
>>> Rachel Golden
>>> Adult Environmental Education Program Manager
>>> Office of Environmental Education
>>> NC Department of Environment and Natural Resources
>>> 1609 Mail Service Center, Raleigh, NC 27699-1609
>>> 919-733-0711 (phone) 919-733-1616 (fax)
>>> rachel.golden at ncmail.net
>>> www.eenorthcarolina.org <http://www.eenorthcarolina.org/>
>>>
>>> Check out the EcoSmart Consumer MySpace page <
>>> http://www.myspace.com/ecosmartconsumer> and blog <
>>> http://ecosmartconsumer.blogspot.com/> !
>>> _______________________________________________
>>> Pharmwaste mailing list
>>> Pharmwaste at lists.dep.state.fl.us
>>>
>>> http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
>>> _______________________________________________
>>> Pharmwaste mailing list
>>> Pharmwaste at lists.dep.state.fl.us
>>>
>>> http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
>>>
>>>
>>>
>>>
>>>
>>> _______________________________________________
>>> Pharmwaste mailing list
>>> Pharmwaste at lists.dep.state.fl.us
>>> http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
>>>
>>>
>>>
>>>
>>> _______________________________________________
>>> Pharmwaste mailing list
>>> Pharmwaste at lists.dep.state.fl.us
>>> http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
>>> _______________________________________________
>>> Pharmwaste mailing list
>>> Pharmwaste at lists.dep.state.fl.us
>>> http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
>>
>>
>> _______________________________________________
>> Pharmwaste mailing list
>> Pharmwaste at lists.dep.state.fl.us
>> http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
>> _______________________________________________
>> Pharmwaste mailing list
>> Pharmwaste at lists.dep.state.fl.us
>> http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
>>
>
>
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