[Pharmwaste] mixtures

Wed Aug 12 13:00:23 EDT 2009

Since most states don't cover pharmwaste under the Universal Waste Rule yet (still a proposed federal rule - see http://www.epa.gov/waste/hazard/wastetypes/universal/pharm.htm ), I recommend you talk with your state agency that regulates hazardous waste to get their interpretation.  They should be able to give you definitive answers to all your questions.

Art Vollmer
Compliance Program Manager
NMED Hazardous Waste Bureau
Phone: (505) 476-6004
P   Please consider the environment before printing.

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Gilliam, Allen
Sent: Wednesday, August 12, 2009 10:31 AM
To: Megan Fakih; pharmwaste at lists.dep.state.fl.us; Susan Zabo
Subject: RE: [Pharmwaste] mixtures

An obvious answer will probably be coming from Charlotte Smith but, liquid wastes can fall under the criteria of haz waste, fyi.  

I'm not conversant on the UW rule so I don't know how all this "mixing" may have fallen out as haz waste regs also include the "mixture rule".  1 oz of liquid P waste mixed with a 55 gallon drum of non-haz waste = 55+ gallons of haz waste to the best of my little haz waste understanding.  Does the UW rule for phamaceuticals bypass or supercede this "mixture rule"?  

§ 261.3 Definition of hazardous waste:(2)(a)(iv) It is a mixture of solid waste and one or more hazardous wastes listed in subpart D of this part and has not been excluded from paragraph (a)(2) of this section under §§ 260.20 and 260.22, paragraph (g) of this section, or paragraph (h) of this section; however, the following mixtures of solid wastes and hazardous wastes listed in subpart D of this part are not hazardous wastes (except by application of paragraph (a)(2)(i) or (ii) of this section) if the generator can demonstrate that the mixture consists of wastewater the discharge of which is subject to regulation under either section 402 or section 307(b) of the Clean Water Act (including wastewater at facilities which have eliminated the discharge of wastewater)..."

Did the UW rule dismiss the "ignitable (I), corrosive (C) and reactive (R) haz waste" chems from this mixture rule?

Allen gilliam
Adeq state pretreatment coordinator

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Megan Fakih
Sent: Wednesday, August 12, 2009 10:42 AM
To: pharmwaste at lists.dep.state.fl.us; Susan Zabo
Subject: Re: [Pharmwaste] (no subject)

Susan,
I am also working to tackle our pharm waste.  In Michigan we have a Universal Waste law which I believe would allow us to co-mingle our hazardous waste (as you described) as long as we know we aren't putting things together that could react.  The only other state that I know has the Universal Waste law is Florida.  I am not an expert on waste labeling but it doesn't sound right that the waste is labeled as solids when you most likely have liquids mixed in there.  

Megan Fakih, RPh, MBA
St Lawrence Campus
Pharmacy Supervisor
1210 W Saginaw St
Lansing, Mi 48915
Phone: (517) 364-6341

>>> Susan Zabo <SusanZ at ohanet.org> 8/12/2009 10:49 AM >>>
A hospital in Ohio is investigating pharm waste. They have received a quote from a company who currently picks up bulk chemo. The company's solution to the pharm waste is to co-mingle all waste with the exception of bulk chemo into one container (toxic, ignitable, corrosive) so the staff does not have to segregate into different boxes. They then incinerate the whole drum of co-mingled hazardous waste under NOS Waste Solids Toxic. I am uncomfortable with this practice and was wondering if anyone has heard of this practice?

Susan Zabo
Project Consultant
Ohio Hospital Association
155 East Broad Street, 15th Floor
Columbus, OH 43215
614.738.2186 - Direct Line
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