[Pharmwaste] DOT Regulations on Pharm Waste?

[Beres, Mark (ECY)]

Good Morning -

The Washington State Department of Ecology has put together a team to
build a policy on pharmwaste that achieves as much regulatory harmony as
possible and to be applied to the regulated community.  Does anyone have
any experience working with the U.S. Department of Transportation with
regards to the transportation of mixed bins of waste drugs?

The Florida Department of Environmental Protection advises the "ORM-D"
placard on its pharmaceutical fact sheets.  Our department's household
take-back pilot will be using "ORM-D" as well, under instructions from a
hazardous waste hauler.  I have also seen Class 6.1 Medicine: liquid,
toxic, n.o.s. and Medicine: solid, toxic, n.o.s.  We are looking to ship
a mixed bin of p-listed, u-listed, state-designating, pills, patches,
IV's, inhalers, maybe regulated medical plus pharmaceutical, maybe
controlled substances, and otherwise waste drugs.  We are wondering if
anyone has asked for and received a fax-back or clarification of some
kind on what the DOT requires for drug waste transportation.

The EPA/DOT joint uniform manifest changed in September 2006 and now
requires up to six waste codes.  We are pushing for as little shipping
regulations as necessary for reasonable transporter safety so that
clinics can throw waste into one bin.  We generally believe that a
"consumer commodity" or "miscellaneous" label is justified for pharm
waste since most substances are inert, frequently transported safely,
and individually packaged.  We also understand that when negotiating
with national organizations (like the DEA), often what we think is
reasonable doesn't mean squat.

Anyone been down this road before?

Thanks for your time,

Mark Beres

Washington State Department of Ecology
Hazardous Waste and Toxics Reduction
425.649.7065
   
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