[Pharmwaste] FW: mixtures

[Tenace, Laurie]

From: Barry Stewart [mailto:bstew01 at msn.com] 
Sent: Wednesday, August 12, 2009 6:50 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: mixtures 

 

An excerpt from 

Environmental

Protection Agency

40 CFR Part 260, 261, 264, et al.

Amendment to the Universal Waste Rule:

Addition of Pharmaceuticals; Proposed

Rule

VerDate Aug<

"Additionally, while the proposal would cover only those wastes that are

hazardous under the RCRA hazardous waste regulations, the streamlined

management requirements may encourage facilities to manage the nonhazardous

portion of the waste stream in a similar manner as the hazardous

portion. That is, it could simplify the waste determination process by

providing, but not requiring, the opportunity for all pharmaceutical

wastes, hazardous or not, to be managed as a single waste stream."

 

 

 

"Furthermore, thousands of pharmaceuticals are approved for use,

so individual generators of hazardous pharmaceutical wastes may generate

hundreds of different types of pharmaceutical waste, some of which

may be regulated as RCRA hazardous, and some of which are not. Sorting out

the RCRA regulated pharmaceutical wastes from the non-hazardous

pharmaceutical wastes at a hospital nursing station or emergency room can

be difficult, and establishing separate collection of these small volumes of

hazardous waste from multiple points within a facility, such as a hospital,
in

particular, can be complicated and burdensome for these generators. In

contrast, industrial generators tend to generate only a few predictable waste

streams in large quantities at relatively few generation points in the
facility."

 

"The Agency expects that the addition of hazardous pharmaceutical wastes to

the UWR will improve the management of such pharmaceutical wastes by

providing a more streamlined waste management system, while ensuring

that they are sent to hazardous waste management facilities for final
disposal.

In addition, this proposed rulemaking would increase the accumulation and

storage time limits in comparison to the full RCRA subtitle C hazardous waste

regulations for hazardous pharmaceutical wastes, which would

allow facilities to accumulate enough waste to make shipment through a

hazardous waste hauler more cost effective. Finally, while not required,

this proposed rulemaking could facilitate the management of non-RCRA

pharmaceutical wastes as universal wastes. If facilities choose to manage

these non-RCRA pharmaceutical wastes as universal wastes, then: (1) Health

care and other regulated facilities would no longer need to identify and
separate

hazardous pharmaceutical wastes from non-hazardous pharmaceutical wastes;

and (2) the regulated community could decide to develop drug take-back

programs, resulting in a decrease in the disposal of pharmaceutical wastes in

municipal solid waste disposal facilities."

 

"UWR will encourage persons to manage other pharmaceutical wastes in the same

manner, particularly those wastes that are not hazardous under RCRA, but

which may nonetheless pose risks. Moreover, EPA expects that including

hazardous pharmaceutical wastes in the UWR will facilitate the implementation

of pharmaceutical take-back programs for retailers and commercial generators

of such wastes, preventing mismanagement. Thus, the Agency

expects that increased quantities of pharmaceutical wastes will be managed

in destination facilities that are subject to the full RCRA subtitle C
regulatory

controls, as opposed to non-hazardous waste landfills and combustors."

 

 

 

 

Actually in EPA's proposed regulations they are suggesting simplification by
combining both waste streams into one- as Universal Pharmaceutical Waste and
also encouraging management of even the non-hazardous pharmaceuticals the
same as the hazardous ones. 

 

Barry E. Stewart
Training Coordinator/ Regional Project Manager

 

HWS, LLC
418 Cypress Road
Ocala, FL 34472
352-680-9400
Fax:  352-680-9406

 

cell: 772-216-6649

 

http:\\hazardouswasteservices.net



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