[Pharmwaste] DOT Regulations on Pharm Waste?

[gressitt at uninets.net]

I went back to look at some of those pages...
Check out:


http://drugterminator.com/incineratorPhoto.htm

I'm attempting to find out more about the Indonesia example.

If the "military can do it?" EPA approved?


Stevan Gressitt, M.D.


>
> Mark:
>
> Technically you'd have to ship then as LQG if the quantities warrant it -
> and list every code on the label, with the items being Lab Packed.
>
> However - you could escape this under the household exclusion with a
> written agreement from your TSDF (Incinerator).
>
> I'd suggest:-  Waste - Consumer medications (Acetomeniphen - Ibuprofen)
> NOS, 6.1, toxic, erg # XXX (dictated by primary hazard on a case by case
> basis).
>
> If you have regulated narcotics, DOT does not really care - but DEA will
> and the restrictions get rather more "intense"
>
> Bill
>
>
>
>              "Beres, Mark
>              (ECY)"
>              <arbe461 at ECY.WA.G                                          To
>              OV>                       <pharmwaste at lists.dep.state.fl.us>
>              Sent by:                                                   cc
>              pharmwaste-bounce
>              s at lists.dep.state                                     Subject
>              .fl.us                    [Pharmwaste] DOT Regulations on
>                                        Pharm Waste?
>
>              02/05/2007 10:43
>              AM
>
>
>
>
>
>
>
> 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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