[Pharmwaste] FW: "Drug Terminator" Followup

[gressitt]

Looking at where they advertise that they  have sold them, I don't recognize
a MN  group. There seem to be some in the neighborhood of others on this
list though. Stevan Gressitt

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Volkman,
Jennifer
Sent: Monday, February 05, 2007 10:49 AM
To: pharmwaste at lists.dep.state.fl.us
Cc: Burman, Joshua
Subject: [Pharmwaste] FW: "Drug Terminator" Followup

Hey all,
This is a reply from a HW regularory person in MN on the Drug Terminator,
based on a message I sent about this portable incinerator.  The response is
based on MN rules, but similar rules likely apply in other states.  
 
I have a question.  See the contraption below.  If I buy one of these and
park it in a neighborhood and go door to door asking for unused/unwanted
pharms from households and burn them up in this thing, am I subject to any
permitting process?  OK, I know it sounds like I'm joking, but many of these
things have been sold.  I am thinking they might be small enough to escape
AQ regulation and it sorta slips by the HHW rules that say waste becomes HW
after it is collected (this would be immediately burned).  Pharms are a big
problem if sewered.  How about if a hospital uses one for destroying its own
non-haz pharms?
www.drugterminator.com <http://www.drugterminator.com/>  

________________________________

From: Burman, Joshua
Sent: Sun 2/4/2007 12:36 PM
To: @PCA Metro County HW Coordinators; Nanette Geroux (E-mail); Marie Olaes;
Zimmer, Catherine; Arthur, Nate; Awad, Fawzi; Berglund, Peter; Bock, Sheryl;
Burman, Joshua; Dyess, Kathy; Freischel, Bill; Jensen, Jennifer; Maurice,
Tanya; Reilly, Karen; Schmidt, Laura; Walter, Rebecca
Cc: 'Adam Frederick'; Bibeau, Christine; Dale, Tina
Subject: RE: "Drug Terminator" Followup


I would like to respond to your queries regarding the "Drug Terminator" in
general and specific: 

- "...If I buy one of these and park it in a neighborhood and go door to
door asking for unused/unwanted pharms from households and burn them up in
this thing, am I subject to any permitting process?..."

= Operation of these units is completely prohibited in Minnesota by all
except hospitals (more on that below).  They are defined as Class IV Waste
Combustors, which are prohibited explicitly by Minn. R. 7011.1220, Subp. 1.

http://www.revisor.leg.state.mn.us/arule/7011/1220.html 
In addition, such an activity would fall squarely into the definitions of
treatment and disposal of solid waste, which is subject to a Solid Waste
Permit by Minn. R. 7001.3050, Subp. 1, Item A.

http://www.revisor.leg.state.mn.us/arule/7001/3050.html 

- "...it sorta slips by the HHW rules that say waste becomes HW after it is
collected (this would be immediately burned)..."

= Though the HW Rules do not explicitly define 'collection', our
interpretation would almost certainly be that the act of accepting the
pharmaceuticals from a household for placement into the burner also
transfers the ownership of the waste to the de-facto HHW Program (burner)
and thus subjects it to the full requirements of Minn. R. 7045.0310, which
would then prohibit disposal by burning through the referral contained in
Subp. 3 to the disposal requirements of Minn. R. 7045.0208.

http://www.revisor.leg.state.mn.us/arule/7045/0310.html 

- "...How about if a hospital uses one for destroying its own non-haz
pharms?..." 
= Theoretically, a hospital may operate a Class IV Waste Combustor (such as
a 'Drug Terminator', 'MediBurn', etc.), however it is subject to the
notification and emissions requirements of Minn. R. 7011.1210, Subp. 2.
These are fairly stringent and would require very expensive testing to
demonstrate prior to allowed operation.  To my knowledge, no hospital in
Minnesota has expressed interest in installing any new incinerators in the
past several years.

http://www.revisor.leg.state.mn.us/arule/7011/1210.html 

*As an aside, the 'Drug Terminator' in specific was designed and is marketed
to law enforcement agencies for disposal of illegal controlled substances.
While such disposal in Minnesota is subject to the full HW Rules, we have
not yet chosen to this point to actively target such operations for
inspection and enforcement.

Thanks. 

Joshua Burman 
Pollution Control Specialist, HW/PCB Programs 
MPCA, Mankato Office 


 

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