[Pharmwaste] Re: Pharmwaste Digest, Vol 36, Issue 11

Tue Oct 14 21:06:27 EDT 2008

William,

I concur with Charlotte's response.  I used Physostigmine Salicylate purely
as an example of a liquid that is an acutely toxic P-Listed waste.  The pH
range is around 3.2-5 which makes it not corrosive by RCRA. 

Jeff Hollar

President

PharmWaste Technologies, Inc.

4164 NW Urbandale Dr., Suite A

Urbandale, IA 50322

(P) 515-276-5302 Ext. 316

(F) 480-393-5564

(E) Jhollar at Pwaste.com

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From: Charlotte A. Smith [mailto:csmith at pharmecology.com] 
Sent: Tuesday, October 14, 2008 7:43 PM
To: William More; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Re: Pharmwaste Digest, Vol 36, Issue 11

Physostigmine is often used in the operation room. No, it does not have a
low pH. Acutely hazardous wastes (P-listed) have an LD50 of 50mg/kg or less.
(oral LD 50 is the dose per kg that kills half the lab animals when
administered orally, usually mice or rats. The lower the LD50, the more
toxic.)  That is, they are considered acutely toxic. There is no correlation
between corrosivity and acute toxicity. They are two very different and
separate definitions of hazardous waste.

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 William More
Sent: Tuesday, October 14, 2008 2:35 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Re: Pharmwaste Digest, Vol 36, Issue 11

How often do you see Physostigmine Salicylate (P188)?  Are you saying it is
also a D002 as it has a low pH?

>>> <pharmwaste-request at lists.dep.state.fl.us> 10/14/08 2:53 PM >>>
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Today's Topics:

   1. RE: Pharmaceutical Corrosives (Jeff Hollar)
   2. FW: Sample prescription drugs (Tenace, Laurie)

----------------------------------------------------------------------

Message: 1
Date: Tue, 14 Oct 2008 11:57:29 -0500
From: "Jeff Hollar" <jhollar at pwaste.com>
Subject: RE: [Pharmwaste] Pharmaceutical Corrosives
To: "'Sue Dayton'" <sdayton at swcp.com>,
<pharmwaste at lists.dep.state.fl.us>
Cc: 'Carolyn Cole' <comet2000 at nc.rr.com>
Message-ID: <006d01c92e1d$f3364840$d9a2d8c0$@com>
Content-Type: text/plain; charset="us-ascii"

Sue,

In our Waste-ID software, we classify pharmaceutical waste as a hazardous
corrosive (D002, yes D002) if it has a pH of less than or equal to 2 or
greater than or equal to

12.5 (40 CFR Part 261.22).  An example of an acutely hazardous liquid
pharmaceutical waste would be Physostigmine Salicylate (P188), as it is a
P-Listed waste.  P-listed wastes are

commercial chemical products which are classified as acutely hazardous under
RCRA.

Jeff Hollar

President

PharmWaste Technologies, Inc.

4164 NW Urbandale Dr., Suite A

Urbandale, IA 50322

(P) 515-276-5302 Ext. 316

(F) 480-393-5564

(E) Jhollar at Pwaste.com

The unauthorized disclosure or interception of e-mail is a federal crime.
See 18 U.S.C. SEC 2517(4). This e-mail is intended for the use of those whom
it is addressed and may contain information that is privileged,
confidential, and exempt from disclosure under the law. If you have received
this e-mail in error, do not distribute or copy it. Please return it
immediately to the sender with attachments, if any, and notify the sender by
telephone.

From: Sue Dayton [mailto:sdayton at swcp.com] 
Sent: Tuesday, October 14, 2008 10:10 AM
To: 'Jeff Hollar'; pharmwaste at lists.dep.state.fl.us
Cc: 'Carolyn Cole'
Subject: RE: [Pharmwaste] Pharmaceutical Corrosives

Hi Jeff:

I have a question for you from a friend - do you know what is the ph level
(or other factor) is for classifying such liquids and solutions as acutely
hazardous vs. hazardous vs non-hazardous?

Thank you!

Sue Dayton

Blue Ridge Environmental Defense League

North Carolina Healthy Communities Program

PO BOX 44

Saxapahaw, NC 27340

(336) 525-2003

sdayton at swcp.com

Our lives begin to end the day we become silent about things that matter.
-  Martin Luther King Jr.

  _____  

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jeff Hollar
Sent: Tuesday, October 14, 2008 10:06 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Pharmaceutical Corrosives

I just posted this on the Practice Greenhealth listserve, but thought it
would be beneficial to many of the members of this Pharmwaste listserve as
well.  

Many of our hospital pharmacy customers are surprised to find out that their
pharmaceutical inventory contains potentially corrosive waste other than a
few compounding chemicals.  One good example of this is Sporanox Solution by
JOM.  A review of the package insert indicates a target pH of 2.   We have
performed internal tests and found the mode average pH to be closer to 1.  A
liquid waste with a pH of 1 is considered corrosive waste by the EPA and
carries an EPA waste code of D003.  It is also considered corrosive when
shipping by the DOT and carries a DOT shipping number of 8.

We have found the pharmaceutical corrosive waste stream to be overlooked in
many of the pharmaceutical inventories that we've analyzed.  For those
pharmacies performing their own waste identification analysis, I would
encourage them to closely review the pH's of the liquids and solutions in
their inventory.  

Jeff Hollar

President

PharmWaste Technologies, Inc.

Urbandale, IA 50322

Email: jhollar at pwaste.com

Website: www.pwaste.com

515-276-5302

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Message: 2
Date: Tue, 14 Oct 2008 14:52:17 -0400
From: "Tenace, Laurie" <Laurie.Tenace at dep.state.fl.us>
Subject: [Pharmwaste] FW: Sample prescription drugs
To: <pharmwaste at lists.dep.state.fl.us>
Cc: ayoungblut at cvmspc.com
Message-ID:
<21FA2802388E16418A98250FDEDB3FDEBFF40C at tlhexsmb5.floridadep.net>
Content-Type: text/plain; charset="us-ascii"

Can anyone help this person?

This question comes up a lot for me. A Florida Statute says, "All
out-of-date
drug samples must be returned to the manufacturer or distributor of that
drug
sample." (Ch. 499.028(9), F.S.) However every drug rep I've asked (just
while
waiting to see doctors at various times) has never heard this and insists
that they do not take back samples. 

Thanks!

Laurie

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
<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
<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.

From: Angie Youngblut [mailto:AYoungblut at cvmspc.com] 
Sent: Tuesday, October 14, 2008 2:39 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: FW: Sample prescription drugs

I have been trying to get one clear answer- and haven't had much success. I
have tried EPA, DNR, Iowa Board of Pharmacy, local landfill and others. I
have expired sample prescription drugs to dispose of and I don't want to
break any regulations, however I have been told I am a "waste generating
facility" and therefore have different rules. It has been recommended to me
to mix them with undesirable substances and put in regular trash and that
they are not considered hazardous.

I do not have the option of giving them to a charitable organization because
they will only take them( in the Iowa Drug Repository program) with a year
left on the expiration and our offices keep them until they expire. 

Is there any clear guideline federally or in Iowa that I have missed? 

Angie Youngblut RN, BS 
Clinical Practice Manager 
Cedar Valley Medical Specialists, P.C. 
4150 Kimball Avenue 
Waterloo, Iowa 50701 
Phone 319-235-5390 
Fax 319-287-9249 
ayoungblut at cvmspc.com

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. Copy the url below to a web browser to complete the
DEP 

survey:
http://survey.dep.state.fl.us/?refemail=Laurie.Tenace@dep.state.fl.us Thank
you in advance for completing the survey.
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