[Pharmwaste] Input/comment requested on categorical classification of hazardous waste/PPCP's and "combustibility."

[Stevan Gressitt]

If one of the characteristics to be considered in the disposal of hazardous
waste is  flammability

And

The proposed method of “incineration” does indeed involve “burning”
explicitly

Then

Why should there not be an exemption for that specific characteristic as a
determinant of hazardous status?

 

 

The situation arose in a discussion with a non-environmental governmental
more law enforcement minded type who was interested in minimizing the
disposal costs through either reverse distributors, hazardous waste
licensees,   or any of the other commercial avenues.

 

I am stumped.

 

Seems there is no reason to apply that standard except in an almost
obsessively narrow minded way to that specific category.

 

I attempted to find an analogy, and without too much caffeine and certainly
below toxic espresso levels, I would ask the following:

 

Some states have liquor monopolies, as in New Hampshire. They sell Rum of
151 proof and absolute ethanol at 195 proof. They collect a state tax on
these bottles and a return fee as well. These are flammable liquids. People
get burned in restaurants from flare ups of fancy meals known as flambe. 

 

Empty containers that held hazardous substances are to be considered as
needing hazardous waste disposal by “Federal?” regulation ( I saw the
citation once but am not familiar with it.) as well as some state
regulations ( I have no reference here either except hearsay.)

 

Hence:

 

1)      All restaurants that serve “flambé” should be required to dispose of
their unused liquor bottles through hazardous waste systems?

2)      All bars that serve over-proof drinks and have empty containers
should dispose of them through hazardous waste?

3)      All bottle return facilities should either a) refuse over-proof
containers or b)segregate the over-proof containers for hazardous waste
disposal

 

 

Besides the lunacy of this line of reasoning, I think I must be missing
something.

 

Or is this another case of “unintended consequences” which is my hunch.

 

Stevan Gressitt, M.D.

 

 

 

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