[Pharmwaste] Household pharms (even haz waste) excluded

Fri Apr 9 07:22:42 EDT 2010

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From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jeff Hollar
Sent: Thursday, April 08, 2010 5:21 PM
To: 'John Lovelace'; 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; scwalters at state.pa.us
Cc: Ross.Bunnell at ct.gov; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Household pharms (even haz waste) excluded

John - Last I heard from an EPA representative, they expect the final rule
to be published around April of 2011, give or take.  Florida and Michigan
are the two states that currently incorporate universal waste rules for
pharmaceuticals.

I know we have some very active listserv members in Florida.  Some could
probably write a book on the subject.  Any takers?

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

-----Original Message-----
From: John Lovelace [mailto:JLOVELACE at gmh.edu]
Sent: Thursday, April 08, 2010 3:40 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: Ross.Bunnell at ct.gov; 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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