[Pharmwaste] Household pharms (even haz waste) excluded

Wed Apr 7 13:05:31 EDT 2010

I know there's non-supporters "out there" for incineration, but I'm surprised to hear more take back programs are not popping up utilizing this exemption.

thanx Ross,

allen g
-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Bunnell, Ross
Sent: Wednesday, April 07, 2010 10:57 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Household pharms (even haz waste) excluded

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/b2213cd1350031738525670f006c22bd!OpenDocument

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/2fd51915214ef63c8525670f006bdc88!OpenDocument

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/3b814bffdbb8f9a28525670f006bda2b!OpenDocument

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/f00b95651a8f5f358525670f006becde!OpenDocument

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