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

[Barry Fernandez]

Stevan,

Wow!  Talk about a 'loaded' question (sorry, I couldn't resist). 

In the case of the 151 or 191 proof liquor analogy, the generator will likely be a conditionally exempt small quantity generator, and therefore exempt from federal (and most local) regulations.  If the bottle contains less than 3% of it's volume by weight, it is considered RCRA empty and can be managed as a solid waste.  I can't fathom a scenario where a bar owner would dispose of any remaining liquor seeing how there is no shortage of people willing to drink mouthwash in order to get their alcohol fix.

I'm not sure what got you worked up, or perhaps I'm missing something, but empty liquor bottles do not fall within the hazardous waste regulation guidelines.  If what you are saying is that New Hampshire has this requirement, I can only suggest that Florida has Cuban coffee, a tolerable climate and real estate prices are at an all time low (although property taxes are out of control).

Best Regards,
Barry

Clean Fuels of Florida, Inc.
D. Barry Fernandez, President
2635 NE 4th Avenue
Pompano Beach, FL 33064
Tel:  954-791-9588
Fax: 954-791-9366
Toll Free: 800-725-8711
barry at clean-fuels.net
www.clean-fuels.net


________________________________

From: Stevan Gressitt [mailto:gressitt at uninets.net]
Sent: Thursday, October 04, 2007 5:37 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Input/comment requested on categorical classificationof hazardous waste/PPCP's and "combustibility."



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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