[Pharmwaste] Re: mixtures

[Barry Stewart]

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 allpharmaceutical

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


Barry Stewart
Sent from my iPhone
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