[Pharmwaste] Household pharms (even haz waste) excluded

[Gilliam, Allen]

It seems there's several lists of "haz waste" going on here.  I've got one of our haz waste division gurus plowing thru several books of pharmaceuticals, comparing them to what might be Fed RCRA haz waste.  So far he's come up with some "P" wastes, but only a few "U".  Characteristic RCRA haz?  He's pulling his hair out...

Again using the pun, I'd hazardous a guess your run of the mill RCRA haz waste inspector could not point to a batch of pills on a table at a take-back program and declare "that's a hazardous waste!  You're busted!"  I dare one step further and say you wouldn't find one our inspectors within a country mile of a pharmaceutical collections project.

I would certainly not advocate drilling around some of these almighty earthsaving RCRA rules and not even cursorily spot check for them with a knowledgeable pharmacist (does one exist without several reference manuals?) plucking out the known RCRA haz waste for separate disposal and incinerating the rest, but this isn't the only instance where the Fed RCRA rules have sanded the vaseline, stymied a common sense good idea for improving our environment and saving even one teenage overdose.

Allen g

ps:  I know I'm driving Charlotte nuts, but I think she knows where I'm coming from...


-----Original Message-----
From: Walters, Scott (DEP) [mailto:scwalters at state.pa.us]
Sent: Thursday, April 08, 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
(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