[Pharmwaste] Question regarding incinerators
gressitt at uninets.net
gressitt at uninets.net
Thu Feb 1 12:46:24 EST 2007
Bill thanks for helping me get this more 'serious." If I am not
consolidating and this is just household, therefore exempt, why am I in
trouble? This is an interessting question because in the past the
discussion has been focused on what the single homeowner czn do (
seemingly unlimited) to what a consolidator could do ( there the EPA, DEA
controls kick in with the state regs as well.)
In this instance however, the situation is more akin to the 19th century
tinkerrer. One family at a time household service to household, one after
another. With no consolidation where would the problerm kick in.
And a second problem is that If as you say I can't dfo it then how come
the municipal ( not a federal or state agency) police do it? I wass
unaware that municipal police were exempt from EPA or state regulatory
rules.
Stevan Gressitt, M.D.
>
> In such a case as the law stands - you'd be in violation of several
> federal
> statutes - from RCRA to possibly the clean air act, and probably a few DEA
> regs as well - the manufacturer - hey - didn't do it - just sold you the
> machine - you're the one that broke the law - you're the one that pays the
> consequences.
>
> Interesting when "corporate rights" exceed those of the individual -
> rights
> that this country was founded upon.
>
> Sidebar Comment:
>
> Actually - as a point of interest - I'm waiting for the one challenge to
> corporate structure that will "blow the entire socio political system
> apart" - it will likely either fundamentally change the way things are
> done
> in the USA or create such apathy with the American Citizen that the slope
> towards ..........may commence.
>
> Ask yourself simply - what would happen if the Supreme Court
> (simplistically) had to adjudicate a case where a citizen raised action
> against the chemical manufacturers association alleging that it's members
> -
> by not properly testing and performing full life cycle analysis of their
> products, were effectively removing said citizens rights to "Life-Liberty
> and the pursuit of Happiness". For example a person with MCS, or one who's
> property was impacted by changing weather patterns through global warming
> might make this claim in a class action? Theoretically one could impeach
> presidents on this (never happen though)
> (MCS - Multiple Chemical Sensitivity)
>
>
>
> gressitt at uninets.
> net
> To
> 02/01/2007 10:46 "Bill Lewry" <Bill_Lewry at kcmo.org>
> AM cc
> "gressitt" <gressitt at uninets.net>,
> pharmwaste at lists.dep.state.fl.us
> Subject
> RE: [Pharmwaste] Question regarding
> incinerators
>
>
>
>
>
>
>
>
>
>
> 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/> !
>>>> _______________________________________________
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>>>>
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>>>>
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>>>>
>>>>
>>>>
>>>>
>>>>
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>>>>
>>>>
>>>>
>>>>
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>>>
>>>
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>>
>>
>
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