[Pharmwaste] Household pharms (even haz waste) excluded

Thu Apr 8 16:43:05 EDT 2010

I believe EPA's target date is Spring 2011.

--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: John Lovelace [mailto:JLOVELACE at gmh.edu] 
Sent: Thursday, April 08, 2010 4:40 PM
To: GILLIAM at adeq.state.ar.us; mirelesmc at earthlink.net;
Thompson.Virginia at epamail.epa.gov;
pharmwaste-bounces at lists.dep.state.fl.us; Stevan.Gressitt at maine.gov;
jhollar at pwaste.com; scwalters at state.pa.us
Cc: Bunnell, Ross; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Household pharms (even haz waste) excluded

Does any one know when the Univeral Waste Rules for Pharmacetuticals are
going to become final?  How are the State Univeral Pharmaceutical waste
rules working out in Florida and Wisconcin?  
-----Original Message----- 
From: "Gilliam, Allen" <GILLIAM at adeq.state.ar.us> 
Cc: Ross' 'Bunnell <Ross.Bunnell at ct.gov> 
To: Matthew C. Mireles <mirelesmc at earthlink.net> 
To: Thompson.Virginia at epamail.epa.gov
<Thompson.Virginia at epamail.epa.gov> 
Cc: pharmwaste at lists.dep.state.fl.us <pharmwaste at lists.dep.state.fl.us> 
To:  <pharmwaste-bounces at lists.dep.state.fl.us> 
To: Stevan' 'Gressitt <Stevan.Gressitt at maine.gov> 
To: Jeff Hollar <jhollar at pwaste.com> 
To: Scott (DEP)' 'Walters <scwalters at state.pa.us> 

Sent: 4/8/2010 9:28:36 AM 
Subject: RE: [Pharmwaste] Household pharms (even haz waste) excluded 

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 
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