[Pharmwaste] Question regarding incinerators
Tenace, Laurie
Laurie.Tenace at dep.state.fl.us
Thu Feb 1 15:59:09 EST 2007
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do not add anything else to this string. No one on digest mode can read any
of these excellent posts and the string is too long for the list serve to
handle.
Remember, when you change the topic you should start a new string with a new
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Thank you
Laurie
Laurie J. Tenace
Environmental Specialist
Florida Department of Environmental Protection
2600 Blair Stone Road, MS 4555
Tallahassee, Florida 32399-2400
PH: (850) 245-8759
FAX: (850) 245-8811
Laurie.Tenace at dep.state.fl.us
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-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
gressitt at uninets.net
Sent: Thursday, February 01, 2007 11:47 AM
To: Bill Lewry
Cc: pharmwaste at lists.dep.state.fl.us; gressitt
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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