[Pharmwaste] Household pharms (even haz waste) excluded

Wed Apr 7 11:57:07 EDT 2010

Allen:

The interpretation you relayed is consistent with EPA's and many state
agencies' interpretation of RCRA.

EPA hazardous waste policy for many years has been that the exemption
from hazardous waste requirements in  40 CFR 261.4(b)(1)  for "household
hazardous waste" applies throughout the waste management cycle.  Briefly
stated, "once an exempt household hazardous waste, always an exempt
household hazardous waste."  Congress put the HHW exemption into RCRA so
that the strict cradle to grave control and facility permitting
requirements that apply to hazardous waste would not apply to the
occasional can of hair spray or rubbing alcohol that we all generate in
our homes.  The reason this interpretation is extended throughout the
management cycle is that, without it, municipal solid waste facilities
that receive small amounts of household hazardous waste in the regular
trash would all have to obtain RCRA Hazardous Waste Facility permits.
EPA does encourage that HHW be sent to hazardous waste facilities as a
best management practice, however.  See the following summaries of EPA
policy documents which support this interpretation (click on the PDF
icon to see the actual document):

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/b2
213cd1350031738525670f006c22bd!OpenDocument

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/2f
d51915214ef63c8525670f006bdc88!OpenDocument 

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/3b
814bffdbb8f9a28525670f006bda2b!OpenDocument

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/f0
0b95651a8f5f358525670f006becde!OpenDocument

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/22
fe8aa0ca59c99c8525693600683ce8!OpenDocument

Here in CT, when we established our HHW collection system many years
ago, we required that operators of one-day collection events or
permanent collection facilities manifest the waste off-site and send it
to a permitted RCRA disposal facility.  We did this because we had heard
that in other states, waste collected at HHW collections was merely
hauled off to a solid waste disposal facility, making its careful
collection and separation from the regular solid waste stream a
pointless exercise, and we wanted to be sure that this didn't happen in
CT.

I think pharmaceuticals might be a horse of a different color, however,
than regular HHW.  Because of their much smaller volume, and the ability
(as expressed in my earlier emails) of municipal solid waste
incinerators to safely handle and destroy them, I think that a different
approach might be environmentally justified.  The cost savings may also
allow much more material to be collected, thereby keeping it out of
medicine cabinets and dumpsters where "pharming" of improperly secured
medications can take place.  Of course, there would still have to be
proper precautions for the security of the collected material until it
is destroyed, to prevent exposure to solid waste facility handlers, and
so forth.  But, I'm not sure that full hazardous waste requirements are
necessary for this waste stream, and may even have a deterrent effect
for collection programs. 

--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

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Gilliam,
Allen
Sent: Wednesday, April 07, 2010 10:45 AM
To: 'Tenace, Laurie'; pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Household pharms (even haz waste) excluded

How many of you have some major heartburn over this? "The following
statement can be made about your household/residential (only) take-back
programs' pharmaceuticals: 'House-hold pharmaceuticals collected through
take-back programs retains its residential hazardous waste exclusion
from collection through final disposal even if disposal is by
incineration.'"

This has recently been coerced out of our haz waste division "experts'"
mouths and hopefully will make octomom look childless once our State
Drug Director gets a full push going on with all the police agencies in
the state. See

https://ardhs.sharepointsite.net/RX for more details.

This state's Office of the Drug Director is approaching take-back
programs from the overdose/abuse viewpoint and seems to be outpacing the
"save the environment" viewpoint by several laps BEGINNING with our law
enforcement partners taking the lead.

Who'd thunk?

Allen g

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