[Pharmwaste] DOT Regulations on Pharm Waste?

[Charlotte A. Smith]

Hi Mark,
 
Is the Dept. of Ecology exempting the household hazardous Rx waste from
regulation as hazardous waste? That makes a big difference. In that
case, I am not sure if ORM-D is sufficient. It seems to me that there
needs to be some indication that waste is involved. 
 
If the household exclusion is not adopted by Washington State, my
experience has been that the ORM-D Consumer Commodity label works for
all pharmaceuticals as products, but once you cross over into waste,
especially when there is hazardous waste, you must fully manifest and
label accordingly. I have seen the label  Waste Medicine, liquid,
flammable, toxic, n.o.s. Packing Group 3 Flammable Liquid UN3248 to
describe a mixed waste stream that contained both toxic and ignitable
hazardous waste. 
 
On a separate note, I would think you would need controlled substances
inventoried and shipped separately if this is a transfer between
registrants? You would not want them mixed into other wastes where they
cannot be properly received and inventoried before disposal by the
registrant taking custody of them. 
 
Hope this helps.
 
Charlotte A. Smith, R. Ph., M.S., HEM
President
PharmEcology Associates, LLC
200 S. Executive Drive, Suite 101
Brookfield, WI 53005
262-814-2635
Fax: 414-479-9941
csmith at pharmecology.com
www.pharmecology.com <http://www.pharmecology.com/> 
H2E Champion for Change Award 
 

________________________________

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Beres,
Mark (ECY)
Sent: Monday, February 05, 2007 10:43 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] DOT Regulations on Pharm Waste?



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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