[Pharmwaste] Re: Pharmwaste Digest, Vol 44, Issue 12

[Matthew Mccarron]

This would seem to call for a "baseline assessment" of the industry's handling practices, so that we can look at "take back" efforts with more informed vision.
 
I would add that we would need the same assessment for:
-long term care facilities
-Skilled nursing/rehabilitation facilities
-mental heath facilities
-Medical Clinics 
-retirement complexes with medial clinics
-veterinary hospital/kennels
-veterinary services for agricultural purposes -livestock/ feed lot/dairy
 
There may be others.
 
 
 
Matt McCarron
Pollution Prevention/Green Business
CA Dept. of Toxic Substances Control
700 Heinz Ave. Suite 300  MS R2 - 2-3
Berkeley, CA 94710
 
510-540-3828
 
Sustaining our resources sustains our future generations


>>> "William More" <wamore at gw.dec.state.ny.us> 6/22/2009 7:57 AM >>>
So what is the present compliance rate with our Hospitals Pharmacies with the RCRA - Hazardous waste regulations? 
How are they achieving Hazardous Waste Determinations? How do they segregate wastes, and when?
How many have a program that know where the stuff that the reverse distributors don't want to take go?  What happens to the waste - contaminated packaging - that comes from dispensing drugs that can be a "P" waste?  Do the reverse distributors(RDs) tell the hospitals about these materials? Do they, the RDs, take these back?
Does that make them a TSDF?  Are they manifested?  What mechanisms are the Hospital Pharmacies using to recover these materials from the patient floors?
What are the RDs doing with those materials that are never credited? The partials that can't be reused because that are not factory sealed?  Those materials that are so far out of date?  The RDs know what they are. Do they pick them up anyway. Does that make them a TSDF? Are they manifested?
 
Have all of the Hospital Pharmacies had their Formulary,(likely stocked Drugs), reviewed as to which ones can be a Hazardous Waste when unusable ,unreturnable, un credited, when a waste. Have they looked for characteristic Hazardous Waste? Mercury compounds that may be used as a preservative? Metals in vitamins or dietary supplements? Alcohol or CFCs in inhalers?
 
What are we seeing when we look at these questions???????
 
 
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