[Pharmwaste] Re: Pharmwaste Digest, Vol 45, Issue 5

Charlotte A. Smith csmith at pharmecology.com
Tue Jul 14 00:01:01 EDT 2009

It would be important to determine if the state in which the drugs are
left at schools would still consider them exempt from the hazardous
waste regulations under the federal household exclusion. That's entirely
possible since they were originally consumer generated. That is probably
a state-by-state decision, similar to the long term care issue.

Best regards, 


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

Director, PharmEcology Services

WM Healthcare Solutions

12229 W. North Ave., Suite 2

Wauwatosa, WI 53226



414-479-9941 (fax)

csmith at pharmecology.com


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



From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of William
Sent: Monday, July 13, 2009 2:08 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Re: Pharmwaste Digest, Vol 45, Issue 5


Thank you for your replies.

I didn't see a Hazardous Waste Determination for the school nurses'
leftover pharmaceuticals?  Its left over, its not reusable, it becomes a
solid waste, the law(RCRA) requires a generator to make a Hazardous
Waste Determination.  How do we communicate that to all the school
nurses? Or to the building principals, or administrators, or the
districts? What are they holding? Did any of them get, Training on
Hazardous Waste Management (RCRA)?  I understand your ,"If there is a
specific policy for the school or school district, that policy should be
followed." That's where review of federal requirements under RCRA
(EPA)should be coming in. And I understand that not all drugs are a
Hazardous Waste. But when we provide direction from the state Health
Depts. and the state Pharmacy Boards, did they get any Training on
Hazardous Waste Management (RCRA)???????




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