[Pharmwaste] Household pharms (even haz waste) excluded

[Gilliam, Allen]

Understood, but sorry.

Would anyone care to take a swag at what % of pharma collections from a take-back program are actually RCRA?  I'd hazard (yep, a pun there) less than 0.5%.

Gressitt?  Mireles?  Whatchoo think?

allen g
-----Original Message-----
From: Thompson.Virginia at epamail.epa.gov [mailto:Thompson.Virginia at epamail.epa.gov]
Sent: Wednesday, April 07, 2010 12:20 PM
To: Gilliam, Allen
Cc: pharmwaste at lists.dep.state.fl.us; pharmwaste-bounces at lists.dep.state.fl.us; 'Bunnell, Ross'
Subject: RE: [Pharmwaste] Household pharms (even haz waste) excluded


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



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