[Pharmwaste] Household pharms (even haz waste) excluded

Wed Apr 7 13:19:47 EDT 2010

Some states (including Pennsylvania) do not apply the household haz waste 
exemption to waste that is brought back together into one location such as 
at a collection event.  The pharmaceutical collection events that have 
been held in PA have required compliance with PA's hazardous waste 
regulations as though the waste had not been household waste.  There may 
be other states that also do not keep the household waste exemption when 
household haz waste is collected. 

Virginia Thompson
Sustainable Healthcare Sector Manager
Office of Environmental Innovation (3EA40)
US Environmental Protection Agency Region 3
1650 Arch Street, Philadelphia, PA  19103
Voice:  (215) 814-5755; Fax (215) 814-2783
thompson.virginia at epa.gov

From:
"Gilliam, Allen" <GILLIAM at adeq.state.ar.us>
To:
"'Bunnell, Ross'" <Ross.Bunnell at ct.gov>, 
"pharmwaste at lists.dep.state.fl.us" <pharmwaste at lists.dep.state.fl.us>
Date:
04/07/2010 01:08 PM
Subject:
RE: [Pharmwaste] Household pharms (even haz waste) excluded

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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