[Pharmwaste] Question regarding incinerators

Bill_Lewry at kcmo.org Bill_Lewry at kcmo.org
Fri Jan 26 15:50:56 EST 2007


Just to clarify one point  many recent and emerging studies (can be found
simply with a web search) are indicating that there are NO safe levels for
dioxin, PCB or mercury containing wastes in the environment  as the effect
is not only cumulative or additive, but often synergistic (see the IJC
report for the great lakes as an example)


                                                                           
             "Taam, Damon"                                                 
             <DTaam at spokanecit                                             
             y.org>                                                     To 
             Sent by:                  <pharmwastebounces at lists.dep.state 
             pharmwastebounce         .fl.us>,                            
             s at lists.dep.state         <pharmwaste at lists.dep.state.fl.us>  
             .fl.us                                                     cc 
                                       rachel.golden at ncmail.net,           
                                       cecilia.deloach at h2eonline.org      
             01/25/2007 07:44                                      Subject 
             PM                        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
noncompliance 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) 6256580 Office
(509) 6256537 Fax

      Original Message
      From:  [mailto:pharmwastebounces 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: pharmwastebounces 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.
      2074410291
      www.mainebenzo.org



      From: pharmwastebounces at lists.dep.state.fl.us
      [mailto:pharmwastebounces 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: pharmwastebounces at lists.dep.state.fl.us;
      pharmwaste at lists.dep.state.fl.us; 'rachel golden'
      Subject: RE: [Pharmwaste] Question regarding incinerators

      Hi all

      Im wondering if any of you are familiar with other acceptable
      treatment technologies for the disposal of nonRCRA 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 nonRCRA pharm waste? Is anyone
      aware of any testing of autoclaves, alkaline hydrolysis, microwaves
      or other treatment technologies for pharm waste?

      Id 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: 8007274179
      Email: cecilia.deloach at h2eonline.org
      www.h2eonline.org

            Original Message
            From: pharmwastebounces at lists.dep.state.fl.us
            [mailto:pharmwastebounces at lists.dep.state.fl.us] On Behalf Of
            Bill Lewry
            Sent: Friday, January 19, 2007 11:23 AM
            To: Volkman, Jennifer
            Cc: pharmwastebounces 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.
            Inactive hide details for "Volkman, Jennifer"
            <Jennifer.Volkman at state.mn.us>"Volkman, Jennifer"
            <Jennifer.Volkman at state.mn.us>


                                                                           
                         "Volkman,                                         
                         Jennifer"                                         
                         <Jennifer.Vol                                     
                         kman at state.mn                                     
                         .us>                                           To 
                         Sent by:                                          
                         pharmwastebo         "rachel golden"             
                         unces at lists.d         <rachel.golden at ncmail.net>, 
                         ep.state.fl.u         <pharmwaste at lists.dep.state 
                         s                     .fl.us>                     
                                                                           
                                                                        cc 
                         01/17/2007                                        
                         03:32 PM                                          
                                                                   Subject 
                                                                           
                                               RE: [Pharmwaste] Question   
                                               regharding incinerators     
                                                                           
                                                                           
                                                                           
                                                                           
                                                                           
                                                                           
                                                                           
                                                                           
                                                                           
                                                                           





            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: pharmwastebounces 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 276991609
            9197330711 (phone) 9197331616 (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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