[Pharmwaste] mixtures

Wed Aug 12 16:21:39 EDT 2009

The Florida Universal Pharmaceutical Waste (UPW) rule doesn't change any of the waste determination requirements, nor does it change DOT shipping/segregation requirements of chemical incompatibilities.  It strips away generator requirements to track and/or report quantities of waste that would trigger a change in generator status (SQG to LQG if generating more than 2.2 lbs of P-Listed waste, for example).  The rule also increases the accumulation time limits and eases other RCRA requirements.  The mixture rule doesn't apply here since the regs make clear that the pharms must be individually packaged (IV, bottle, ampoule, tube, etc.).  Drug co-mingling is generally uncommon if properly done (education is key).

As to segregation and the "all-in-one" packaging, so long as the materials are chemically compatible, it should conform to RCRA and DOT.  We call this "single stream management".  Whereas, rather than segregate haz from non-haz; and segregate the haz into various RCRA classes and types, all pharmaceuticals (with the exception of the very rare incompatibles such as corrosives, oxidizers and reactive) combined into a single stream.  Currently, the shipping description of "Waste Medicine, liquid, flammable, toxic, n.o.s.", for lack of a better shipping description in the HMT, seems to be most common and applicable.

I've heard the argument that single-stream management increases costs because the waste is ultimately all being treated as RCRA once it leaves Florida.  This is true if you compare dollar-for-dollar disposal cost alone.  However, considering the simplicity of a single stream program, the waste (formulary) characterization dollars, money and resources to label everything in inventory, the training of nursing and other staff, labor to segregate, the level of compliance achieved, etc. it pales in comparison when you look at the overall program budget as a whole.  Say nothing of the fact that many, many drugs not regulated under RCRA slip into municipal landfills and wastewater treatment plants, yet pose a significant threat to human health and the environment.  The benefits to the tradeoff are actually cheaper in the long run.

For those interested, here is a link to Florida's UPW rule.  It's a fairly easy read as far as regulations go:  http://pharmtag.org/62730186.pdf

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: Gilliam, Allen [mailto:GILLIAM at adeq.state.ar.us]
Sent: Wednesday, August 12, 2009 12:31 PM
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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