FW: [Pharmwaste] Household pharms (even haz waste) excluded

Thu Apr 8 09:13:01 EDT 2010

From: Matthew C. Mireles [mailto:mirelesmc at earthlink.net]
Sent: Thursday, April 08, 2010 9:07 AM
To: Walters,Scott (DEP); cssrinivasan at communityofcompetence.com; 'Jeff Hollar'; 'Gilliam,Allen'; Thompson.Virginia at epamail.epa.gov; 'Gressitt,Stevan'
Cc: pharmwaste-bounces at lists.dep.state.fl.us; 'Bunnell,Ross'; easmith at communityofcompetence.com; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Household pharms (even haz waste) excluded

That would be an interesting research question.  Since very few pharmaceutical products are actually classified as RCRA waste except those classes already mentioned (e.g. chemotherapeutics, antineoplastics, and radioactive isotopes, etc.), this classification system may be limited.  For environmental hazard and risk assessment and classification, we use the JANUS INFO system that is based on more accurate and controlled risk assessment methodology including systematic histological examination of aquatic species.  I think our EPA started just started a similar program.  Even JANUS INFO does not cover 100% of the drugs on the European market, but by far it's the most usable classification for suspect drugs with relatively high potential of deleterious effects in the environment.  Of course, we are talking about the endocrine disruptors, antibiotics, and others.

ENVIRONMENTAL RISK refers to risk of acute toxicity to the aquatic environment. Environmental risk is based on the ratio of predicted environmental concentration of the substance (PEC) and the highest concentration of the substance that does not have a harmful effect in the environment (PNEC).  The potential ENVIRONMENTAL HAZARD assessment of an active pharmaceutical substance is based on the three characteristics of persistence (P), bioaccumulation (B), and toxicity (T). Each characteristic is assigned a numeric value (0–3). The total of the values comprises the PBT Index of the substance.  Environmental hazard assessment is based on the JANUS Classification System, accessed at http://www.janusinfo.se/imcms/servlet/GetDoc?meta_id=6913.

We have standardized our National Unused and Expired Medicines Registry to the JANUS INFO for now and we expect to begin cross national comparison very soon.  If the EPA or any other agency in the US has a comparable classification system, please let us know.

Additionally, we are cross referencing returned unused and expired meds with OSHA hazardous materials for possible exposure, and very few drugs showed up.

BMP...best management practices...something we don't see too often.  I add some more terms to think about:

precautionary principle

product stewardship

social responsibility

environmental sustainability

REACH

Jeff Hollar, I may take you up on your offer and check our UEM data from the Registry with your RCRA list.  I believe our research team did this several years ago and we determined that RCRA was not adequate in the kind and level of coding we needed to do for the Registry.  But I'm willing to look at it again.

Matthew Mireles

-----Original Message-----
From: "Walters, Scott (DEP)"
Sent: Apr 8, 2010 7:36 AM
To: 'Jeff Hollar' , "'Gilliam, Allen'" , "Thompson.Virginia at epamail.epa.gov" , "'Matthew C. Mireles'" , "'Gressitt, Stevan'"
Cc: "pharmwaste-bounces at lists.dep.state.fl.us" , "'Bunnell, Ross'" , "pharmwaste at lists.dep.state.fl.us"
Subject: RE: [Pharmwaste] Household pharms (even haz waste) excluded

I wonder if some of the regulated medical waste companies would have that information.  Some of them also collect pharmaceuticals.
-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jeff Hollar
Sent: Wednesday, April 07, 2010 5:21 PM
To: 'Gilliam, Allen'; Thompson.Virginia at epamail.epa.gov; 'Matthew C. Mireles'; 'Gressitt, Stevan'
Cc: pharmwaste-bounces at lists.dep.state.fl.us; 'Bunnell, Ross'; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Household pharms (even haz waste) excluded
We have found that around 4% of an inpatient pharmacy’s formulary is RCRA waste, when discarded.  Not all of those items are used by households.  However, let’s not forget about the BMP (Best Management Practices) waste.  Think of all the chemo drugs alone that would be classified as RCRA waste if RCRA was updated.

If anyone is interested in running a test to determine the amount of RCRA waste collected at their next collection event, let me know (off of the listserve).  We will help out with the identification side and share the results with the rest of the group.

Jeff Hollar
President

PharmWaste Technologies, Inc.
4164 NW Urbandale Dr., Suite A
Urbandale, IA 50322
(P) 515-276-5302 Ext. 316
(D) 515-331-7310
(F) 480-393-5564
(E) Jhollar at Pwaste.com<mailto:Jhollar at Pwaste.com>
(W) www.pwaste.com

From: Gilliam, Allen [mailto:GILLIAM at adeq.state.ar.us]
Sent: Wednesday, April 07, 2010 1:20 PM
To: 'Thompson.Virginia at epamail.epa.gov'; 'Matthew C. Mireles'; 'Gressitt, Stevan'
Cc: pharmwaste-bounces at lists.dep.state.fl.us; 'Bunnell, Ross'; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Household pharms (even haz waste) excluded

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

-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20100408/946f0d03/attachment.html