[Pharmwaste] FW: appropriate disposal of expired drugs

Tue Oct 7 10:54:06 EDT 2008

Hi Laurie,

I agree with Charlotte and Catherine.  Here in Florida, even Conditionally Exempt Small Quantity Generators (CESQG) must manage their wastes in accordance with RCRA regulations where applicable.  From the FL DEP Website:

http://www.dep.state.fl.us/waste/categories/hazardous/pages/cesqg.htm
"CESQGs generate less than 100 kilograms of HW per month and less than 1 kilogram of acute HW (such as some pesticides, toxins or arsenic and cyanide compounds) per month.  Many wastes that are recycled are included in this quantity determination.

Requirements:  [updated 08-14-06]
- Perform HW determination.  [§262.11]
- Cannot accumulate > 1000 kg at any time.  [§261.5(g)(2)]
- Ensure delivery of HW to a proper recycling facility or TSDF.  [§261.5(g)(3)]
- Keep records documenting proper disposal.  [§62-730.030(3) & (4), F.A.C.] "

The good news for folks in Florida and Michigan are the Universal Pharmaceutical Waste (UPW) regulations. Managing pharms as UPW in these states eases some of the regulatory burdens, in turn making the cost of compliance affordable.  Not to mention that it encourages good environmental stewardship and keeps these meds out of our waterways.  Water which, by the way, she possibly consumes.

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
Cell:  305-216-4941
Toll Free: 800-725-8711
barry at clean-fuels.net
www.clean-fuels.net

-----Original Message-----
From: zimme053 at umn.edu [mailto:zimme053 at umn.edu]
Sent: Tuesday, October 07, 2008 9:39 AM
To: Charlotte A. Smith
Cc: APittman at HCNetwork.org; Tenace, Laurie; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] FW: appropriate disposal of expired drugs

Hi Laurie, Charlotte and all,
In MN, the MN Pollution Control Agency, who writes the permits for wastewater treatment plants (aka POTW) , advised all the plants to not accept pharmaceuticals. Because most pharmaceuticals pass through the plant directly into surface waters, by accepting them, the POTW could be violating the terms of their permits.

For management, they have a few options: manage as hazardous waste (most compliant), manage as medical waste and send to incinerator, manage as solid waste (if they have an incinerator) or take to a Very Small Quantity Generator collection or household HW collection site I know they are not generally wanted there, but when the option is sewer.....?

Again, of course, the best option is to not generate the waste pharmaceuticals in the first place, and I think we need to continue to plant the seed and keep beating that drum.

--
Catherine Zimmer
Health Care Specialist

Minnesota Technical Assistance Program
University of Minnesota
phone 612/624-4635
http://www.mntap.umn.edu

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

On Oct 6 2008, Charlotte A. Smith wrote:

>The Wisconsin DNR has come up with a grid defining the type of facility
>that they consider a business versus a "home" with respect to the
>enforcement of RCRA. It is our understanding WDNR expects businesses to
>comply with existing hazardous waste regulations, including
>pharmaceuticals. You can access the website at
>http://dhs.wisconsin.gov/rl_dsl/Publications/pdfmemos/08-003attch.pdf
>
>
>
>I hope this is helpful.
>
>
>
>Best regards,
>
>
>
>
>
>Charlotte A. Smith, R. Ph., M.S., HEM
>
>President
>
>PharmEcology Associates, LLC
>
>12229 W. North Ave., Suite 2
>
>Wauwatosa, WI 53226
>
>414-292-3959
>
>414-915-4026 (cell)
>
>csmith at pharmecology.com
>
>www.pharmecology.com
>
>________________________________
>
>From: pharmwaste-bounces at lists.dep.state.fl.us
>[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Tenace,
>Laurie
>Sent: Monday, October 06, 2008 3:19 PM
>To: pharmwaste at lists.dep.state.fl.us
>Cc: APittman at HCNetwork.org
>Subject: [Pharmwaste] FW: appropriate disposal of expired drugs
>
>
>
>Here is a question from a non-member of the list serve. But I think it
>is a good question for us to discuss and I'd like to hear of any
>solutions other states have come up with for clinics, nursing homes,
>vets - the people that kind of fall through the cracks - not covered by
>homeowner's exemptions but not big enough to use reverse distribution.
>I hate to tell them about RCRA and that they need incur costs to
>dispose of their drugs and have been told on more than one occasion
>that they are going to keep flushing their meds until I come up with a
>regulation that says they can't.
>
>
>
>Any good solutions out there? Or does anyone have regulations that help
>these very small generators?
>
>
>
>Laurie J. Tenace
>Environmental Specialist
>Florida Department of Environmental Protection 2600 Blair Stone Road,
>MS 4555 Tallahassee, Florida 32399-2400
>PH: (850) 245-8759
>FAX: (850) 245-8811
>Laurie.Tenace at dep.state.fl.us
>
>Mercury web pages:
>http://www.dep.state.fl.us/waste/categories/mercury/default.htm
>
>Unwanted Medications web pages:
>http://www.dep.state.fl.us/waste/categories/medications/default.htm
>
>
>
>
>Please Note:  Florida has a very broad public records law.  Most
>written communications to or from state officials regarding state
>business are public records available to the public and media upon
>request.  Your e-mail is communications and may therefore be subject to
>public disclosure.
>
>
>
>
>
>
>
>
>The Department of Environmental Protection values your feedback as a
>customer. DEP Secretary Michael W. Sole is committed to continuously
>assessing and improving the level and quality of services provided to
>you. Please take a few minutes to comment on the quality of service you
>received. Simply click on this link to the DEP Customer Survey
><http://survey.dep.state.fl.us/?refemail=Laurie.Tenace@dep.state.fl.us>
>. Thank you in advance for completing the survey.
>
>From: Pittman, Anita [mailto:APittman at HCNetwork.org]
>Sent: Monday, October 06, 2008 12:49 PM
>To: pharmwaste at lists.dep.state.fl.us
>Subject: appropriate disposal of expired drugs
>
>
>
>What is the appropriate and acceptable disposal policy for prescription
>and over the counter drugs  in a small clinic (non-narcotic)
>
>Thank you
>
>DISCLAIMER:
>This information, including any attachments, may contain legally
>privileged and/or highly confidential information. If you are not the
>intended recipient(s), or the employee responsible for delivery of this
>message to the intended recipient(s), you are hereby notified that any
>dissemination, distribution or copying of this communication is
>strictly prohibited under State and Federal Laws. If you have received
>this communication in error, please immediately notify the sender and
>follow appropriate actions for disposal.
>
>

 <http://e-mail-servers.com/3954d66db720ab2e29d02d0135d2fa0fworker.jpg> 
-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20081007/0aaf1768/attachment.htm