[Pharmwaste] Question regarding incinerators

Damro_WW Damro_WW at co.brown.wi.us
Fri Jan 26 16:35:40 EST 2007


Pharmaceuticals, like other materials, become a waste when the user or
generator decides the material is no longer useful.  At this point any
waste that is hazardous in nature becomes a hazardous waste.  

Most States exempt household hazardous waste so that it does not need to
be managed as a hazardous waste.

Wess Damro
Brown County Recycling Manager

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Matthew
Mireles
Sent: Friday, January 26, 2007 3:32 PM
To: zimme053 at umn.edu; 'Taam, Damon'
Cc: rachel.golden at ncmail.net; pharmwaste-bounces at lists.dep.state.fl.us;
cecilia.deloach at h2e-online.org; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Question regarding incinerators

Has anyone addressed the problem of hazardous waste (drugs) from the
home?
When do pharmaceuticals actually become a hazardous waste?  

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Catherine
Zimmer
Sent: Friday, January 26, 2007 3:03 PM
To: Taam, Damon
Cc: pharmwaste-bounces at lists.dep.state.fl.us;
cecilia.deloach at h2e-online.org; pharmwaste at lists.dep.state.fl.us;
rachel.golden at ncmail.net
Subject: Re: [Pharmwaste] Question regarding incinerators

Currently there are two hazardous waste facilities that are permitted by

both EPA and DEA to take and incinerate controlled substances. The Clean

Harbors facility in Argonite Utah and I believe, Veolia Environmental 
Services. However, after hearing some comments at a meeting a few weeks 
ago from a Veolia representative suggesting ways hospitals can avoid 
hazardous waste regulation, I would be cautious.


Catherine Zimmer
Health Care Specialist

Minnesota Technical Assistance Program
University of Minnesota
612/624-4635, 800/247-0015
http://www.mntap.umn.edu

Helping Minnesota businesses maximize resource efficiency, prevent
pollution
and reduce costs.



Taam, Damon wrote:
> 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 <http://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 <http://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.
>     Inactive hide details for "Volkman, Jennifer"
>     <Jennifer.Volkman at state.mn.us>"Volkman, Jennifer"
>     <Jennifer.Volkman at state.mn.us>
>
>     *"Volkman, Jennifer" <Jennifer.Volkman at state.mn.us>*
>     Sent by: pharmwaste-bounces at lists.dep.state.fl.us
>
>     01/17/2007 03:32 PM
>
>     	
>
>     To
>
>     	
>
>
>     "rachel golden" <rachel.golden at ncmail.net>,
>     <pharmwaste at lists.dep.state.fl.us>
>
>     cc
>
>     	
>
>     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: 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/> !
>     _______________________________________________
>     Pharmwaste mailing list
>     Pharmwaste at lists.dep.state.fl.us
>     http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
>
>
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>
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