[Pharmwaste] Question regarding incinerators

Pickrel.Jan at epamail.epa.gov Pickrel.Jan at epamail.epa.gov
Fri Jan 26 12:12:42 EST 2007


"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:
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                               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:
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                               fl.us         (Embedded image moved to
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                                       (Embedded image moved to file:
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                               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
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            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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