[Pharmwaste] Question regarding incinerators
kcrecycling at earthlink.net
kcrecycling at earthlink.net
Tue Jan 30 13:32:30 EST 2007
I like your idea Jennifer! It could simplify the collection process---no
need for a deputy officer to take the "controlled stuff"---but how do the
legalities play out?
kcrecycling at earthlink.net
EarthLink Revolves Around You.
Sue Studebaker, Director
> [Original Message]
> From: Volkman, Jennifer <Jennifer.Volkman at state.mn.us>
> To: <Pickrel.Jan at epamail.epa.gov>; Matthew Mireles
<mirelesmc at earthlink.net>
> Cc: Vizzier, Michael <Michael.Vizzier at sdcounty.ca.gov>;
<pharmwaste at lists.dep.state.fl.us>
> Date: 1/29/2007 4:36:38 PM
> Subject: RE: [Pharmwaste] Question regarding incinerators
>
> OK, another thought on this, maybe it has been thrown out already
> somewhere in the past and eliminated for reasons that I can probably
> come up with on my own... :)
>
> How about if we have patients rip off all labels, mix all their pills
> and liquids together with vinegar and bring/mail them in for collection.
> The meds are effectively destroyed/unidentifiable so DEA won't be
> excited. The collectors ship them to a HW incinerator in lab packs
> labeled as D001/poisons/pesticides, or the most appropriate DOT hazard
> class for the mixture.
>
> Participants can stick the labels with their name/number blacked out to
> a sheet of paper with an estimation on the count/quantity for each if
> the collector would like to share that info with a program like the
> Unused and Expired Medicines Registry.
>
> If we make it simple enough for collectors, maybe more will do it.
>
> -----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 11:13 AM
> To: Matthew Mireles
> Cc: 'Vizzier, Michael'; pharmwaste at lists.dep.state.fl.us
> Subject: RE: [Pharmwaste] Question regarding incinerators
>
>
> "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:
> <Jennif pic27799.gif)
> 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:
> sts.dep pic07701.gif)
> .state. cc
> fl.us (Embedded image moved to
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> (Embedded image moved to file:
> 01/17/2 pic04404.gif)
> 007 Subject
> 03:32 (Embedded image moved to
> PM file: pic15729.gif)
> RE: [Pharmwaste] Question
> regharding incinerators
>
>
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>
>
>
> (Embedded image moved to file:
> pic19215.gif)
> (Embedded image moved to
> file: pic30565.gif)
>
>
>
>
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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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