[Pharmwaste] Green OIl question

Charlotte A. Smith csmith at pharmecology.com
Fri Aug 21 13:52:14 EDT 2009


Many times the manufacturer either goes out of business and or sales drop to the point where it is no longer a viable product. It would be difficult to know given the age of the item.

 

Best regards, 

 

Charlotte A. Smith, R. Ph., M.S., HEM

Director, PharmEcology Services

WM Healthcare Solutions, Inc.

12229 W. North Ave., Suite 2

Wauwatosa, WI 53226

414-292-3959

414-915-4026(cell)

414-479-9941 (fax)

csmith at pharmecology.com

 

Waste Management's renewable energy projects create enough energy to power over 1 million homes.

 

 

From: Gressitt, Stevan [mailto:Stevan.Gressitt at maine.gov] 
Sent: Friday, August 21, 2009 11:38 AM
To: Bunnell, Ross; Thomas Hodges; pharmwaste at lists.dep.state.fl.us; Tim Glover; Charlotte A. Smith
Subject: RE: [Pharmwaste] Green OIl question

 

Actually one of my unanswered questions here is how was it removed from the market, who or what decreed it as no longer available FDA? DEA? EPA? Some other group of letters? 

 

Stevan Gressitt, M.D., Medical Director

Office of Adult Mental Health Services

Department of Health and Human Services

Marquardt Building, 2nd Floor

11 State House Station

32 Blossom Lane

Augusta, ME  04333-0011

Ph: (207)287-4273

Fax: (207)287-1022

Cell Phone: (207) 441-0291

E-Mail : stevan.gressitt at maine.gov <mailto:stevan.gressitt at maine.gov> 

http://www.maine.gov/dhhs/mh/ <http://www.maine.gov/dhhs/mh/> 

 

Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s).  It may contain confidential and privileged information.  Any unauthorized review, copy, use, disclosure, or distribution is prohibited.  If you are not the intended recipient, please note that any dissemination, distribution or copying of this is strictly prohibited.  Please contact me by reply e-mail or telephone and destroy all copies of this message.

The Department of Health and Human Services (DHHS) does not discriminate on the basis of disability, race, color, creed, gender, sexual orientation, age, or national origin, in admission to, access to, or operations of its programs, services, or activities, or its hiring or employment practices.  This notice is provided as required by Title II of the Americans with Disabilities Act of 1990 and in accordance with the Civil Rights Act of 1964 as amended, Section 504 of the Rehabilitation Act of 1973, as amended, the Age Discrimination Act of 1975, Title IX of the Education Amendments of 1972 and the Maine Human Rights Act and Executive Order Regarding State of Maine Contracts for Services.  Questions, concerns, complaints or requests for additional information regarding the ADA may be forwarded to DHHS' ADA Compliance/EEO Coordinators, 11 SHS-221 State Street, Augusta, Maine 04333, 207-287-4289 (V), 207-287-3488 (V), 1-800-606-0215 (TTY).  

 

 

________________________________

From: Bunnell, Ross [mailto:Ross.Bunnell at ct.gov] 
Sent: Friday, August 21, 2009 12:29 PM
To: Thomas Hodges; pharmwaste at lists.dep.state.fl.us; Tim Glover; Gressitt, Stevan; Charlotte A. Smith
Subject: RE: [Pharmwaste] Green OIl question

 

I agree with shipping it as a D022 hazardous waste, but the U044 code (for commercial chemical product chloroform) would not apply.  As noted in a comment at the end of 40 CFR 261.33(d):

[Comment: The phrase "commercial chemical product or manufacturing chemical intermediate having the generic name listed in .  .  ." refers to a chemical substance which is manufactured or formulated for commercial or manufacturing use which consists of the commercially pure grade of the chemical, any technical grades of the chemical that are produced or marketed, and all formulations in which the chemical is the sole active ingredient. It does not refer to a material, such as a manufacturing process waste, that contains any of the substances listed in paragraph (e) or (f). Where a manufacturing process waste is deemed to be a hazardous waste because it contains a substance listed in paragraph (e) or (f), such waste will be listed in either §261.31 or §261.32 or will be identified as a hazardous waste by the characteristics set forth in subpart C of this part.] (emphasis added)

The chloroform in this product is not the "sole active ingredient," but only one of several active ingredients, including, as noted on the label, "peppermint [oil], methyl salicylate, and chlorophyll."  Hence, the U044 code does not apply.

--Ross Bunnell, Sanitary Engineer 3

CT Department of Environmental Protection (DEP)

Bureau of Materials Management and Compliance Assurance

Waste Engineering & Enforcement Division

Tel.  860.424.3274

Fax  860.424.4059

ross.bunnell at ct.gov

 

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Thomas Hodges
Sent: Friday, August 21, 2009 11:58 AM
To: pharmwaste at lists.dep.state.fl.us; Tim Glover; Stevan Gressitt; Charlotte A. Smith
Subject: RE: [Pharmwaste] Green OIl question

 

I would ship it out as hazardous waste.  EPA codes D022 and U044.  When (or how long you can keep it after making this waste determination) depends on your generator status (CESQG, SQG or LQG).

 

Regards,

Tom

 

Thomas Hodges, CHMM
Hazardous Materials Manager
Environmental Safety & Health
971 Camp Auburn Road
Auburn University, Alabama  36849
334.703.7511     334.844.4805
FAX  334.844.4197
hodgetf at auburn.edu

"The barn burnt down.  Now I can see the moon."  ~ Mizuta Masahide 



>>> On 8/21/2009 at 10:37 AM, in message <0F9DE263E5900443A7E41D687174316703601D18 at SOM-TEAQASMAIL6.som.w2k.state.me.us>, "Gressitt, Stevan" <Stevan.Gressitt at maine.gov> wrote:

Charlotte this clearly says internal only so is different see picture

Stevan Gressitt, M.D., Medical Director
Office of Adult Mental Health Services
Department of Health and Human Services
Marquardt Building, 2nd Floor
11 State House Station
32 Blossom Lane
Augusta, ME  04333-0011
Ph: (207)287-4273
Fax: (207)287-1022
Cell Phone: (207) 441-0291
E-Mail : stevan.gressitt at maine.gov
http://www.maine.gov/dhhs/mh/

Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s).  It may contain confidential and privileged information.  Any unauthorized review, copy, use, disclosure, or distribution is prohibited.  If you are not the intended recipient, please note that any dissemination, distribution or copying of this is strictly prohibited.  Please contact me by reply e-mail or telephone and destroy all copies of this message.



-----Original Message-----
From: Charlotte A. Smith [mailto:csmith at pharmecology.com] 
Sent: Friday, August 21, 2009 10:04 AM
To: Glover, Tim; Gressitt, Stevan; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Green OIl question

Hi Everyone,

I suspect this may be the same as Hein Fong or Green Drops, a popular carminative in the 40s and 50s. It was even made in Milwaukee as Geisecke's Green Essence and was an aqueous/alcoholic solution that contained chloroform along with a number of other ingredients with a strong mint flavor. I took it as a kid for indigestion. I don't recall the alcohol content. You may want to manage it as a hazardous waste due to the chloroform and alcohol but it is relatively innocuous. 

Best regards, 

Charlotte A. Smith, R. Ph., M.S., HEM
Director, PharmEcology Services
WM Healthcare Solutions, Inc.
12229 W. North Ave., Suite 2
Wauwatosa, WI 53226
414-292-3959
414-915-4026(cell)
414-479-9941 (fax)
csmith at pharmecology.com

Waste Management's renewable energy projects create enough energy to power over 1 million homes.



-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Glover, Tim
Sent: Friday, August 21, 2009 8:35 AM
To: Gressitt, Stevan; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Green OIl question

If my memory serves me correctly, "Green Oil" also is used as a name for a coal-tar distillation produce (perhaps anthracene oil?).  The manufacturing date you posed is consistent with this name usage too.


Tim Glover 
Senior Environmental Scientist - Geochemistry 
Geoscience Department Atlanta Area 
MACTEC Engineering and Consulting, Inc. 
Kennesaw, Georgia, USA 
Office 770-421-3310 
Fax 770-421-3486 
Email ntglover at mactec.com 
Web www.mactec.com 


From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Gressitt, Stevan
Sent: Thursday, August 20, 2009 12:08 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Green OIl question

A question has arisen over disposal of a bottle of Green Oil, probably manufactured in 1950 or earlier that comes from a now defunct pharmacy. Main active ingredient is chloroform, percentage unknown. Thoughts? Also legality as it does not appear to be a controlled drug...but not available for current purchase? 

Stevan Gressitt, M.D., Medical Director
Office of Adult Mental Health Services
Department of Health and Human Services
Marquardt Building, 2nd Floor
11 State House Station
32 Blossom Lane
Augusta, ME  04333-0011
Ph: (207)287-4273
Fax: (207)287-1022
Cell Phone: (207) 441-0291
E-Mail : stevan.gressitt at maine.gov
http://www.maine.gov/dhhs/mh/

Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s).  It may contain confidential and privileged information.  Any unauthorized review, copy, use, disclosure, or distribution is prohibited.  If you are not the intended recipient, please note that any dissemination, distribution or copying of this is strictly prohibited.  Please contact me by reply e-mail or telephone and destroy all copies of this message.
The Department of Health and Human Services (DHHS) does not discriminate on the basis of disability, race, color, creed, gender, sexual orientation, age, or national origin, in admission to, access to, or operations of its programs, services, or activities, or its hiring or employment practices.  This notice is provided as required by Title II of the Americans with Disabilities Act of 1990 and in accordance with the Civil Rights Act of 1964 as amended, Section 504 of the Rehabilitation Act of 1973, as amended, the Age Discrimination Act of 1975, Title IX of the Education Amendments of 1972 and the Maine Human Rights Act and Executive Order Regarding State of Maine Contracts for Services.  Questions, concerns, complaints or requests for additional information regarding the ADA may be forwarded to DHHS' ADA Compliance/EEO Coordinators, 11 SHS-221 State Street, Augusta, Maine 04333, 207-287-4289 (V), 207-287-3488 (V), 1-800-606-0215 (TTY).  

________________________________________

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