[Pharmwaste] Federal Incineration Reg

Barry Fernandez Barry at clean-fuels.net
Mon Sep 13 12:50:13 EDT 2010


Sorry Pamela, but I believe RCRA permitted incinerators are pretty
consistent across the board and across politics.  In fact, EPA has an
on-site office at most of them. 
 
Clean Fuels of Florida, Inc.
D. Barry Fernandez, President
2635 NE 4th Avenue
Pompano Beach, FL 33064
Tel: 954-791-9588
Fax: 954-791-9366
Cell: 305-216-4941
Toll Free: 800-725-8711
barry at clean-fuels.net <mailto:barry at clean-fuels.net> 
www.clean-fuels.net <http://www.clean-fuels.net/>  

________________________________

From: Pamela Ortner [mailto:portner at angelahospice.net] 
Sent: Monday, September 13, 2010 12:17 PM
To: Popichak, Robert; Sue Dayton; 'Al White'; 'gressitt'; 'Holcomb,
Sarah, NMENV'
Cc: Hyatt, Thomas; Michael Stepaniak; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Federal Incineration Reg


Unfortunately,  in order to maintain the high level temperature,
maintenance and enforcement is extremely important which varies from
state to state, city to city and administration to adminstration.
 
Pamela Ortner, MS, RN, CHPN, COHN-S
Quality Outcomes/Education Coordinator
Angela Hospice
14100 Newburgh Rd.
Livonia, Michigan 48154
(734) 953-6040
 
"Willing is not enough, we must act.  Knowing is not enough, we must
do."
 
Goethe                             
 
 
 
----- Original Message ----- 
	From: Popichak, Robert <mailto:rpopichak at state.pa.us>  
	To: Sue Dayton <mailto:sdayton at swcp.com>  ; 'Al White'
<mailto:biosun at npacc.net>  ; 'gressitt' <mailto:gressitt at zoho.com>  ;
'Holcomb, Sarah, NMENV' <mailto:sarah.holcomb at state.nm.us>  
	Cc: Hyatt, Thomas <mailto:thyatt at state.pa.us>  ; Michael
Stepaniak <mailto:michaels at ccicenter.org>  ;
pharmwaste at lists.dep.state.fl.us 
	Sent: Tuesday, July 13, 2010 6:42 AM
	Subject: RE: [Pharmwaste] Federal Incineration Reg

	Good Morning, all-greetings from Pittsburgh!
	 
	        As a chemist, I had to jump in and correct a huge
misconception-microwave and autoclave treatment are sterilization
methods-they do not chemically destroy the compounds in question as
would a PROPERLY OPERATING, MAINTAINED, AND MONITORED high-temperature
hazardous waste incinerator.  The air pollution control devices are
orders of magnitude more efficient than either of the aforementioned
methods, which essentially have little to none.  W2E furnaces NORMALLY
are less efficiently destructive due to lower temperature and dwell
times.
	 
	        Hope this helps and we compare McIntosh to Gala and not
bananas to coconuts!
	 
	        Have a great Tuesday!
	 
	Bob 
	Robert Popichak | Environmental Chemist I
	Department of Environmental Protection
	Southwest Regional Office
	400 Waterfront Drive | Pittsburgh, PA 15222-4745
	Phone: 412.442.4160 | Fax: 412.442.4194 
	rpopichak at state.pa.us
	www.depweb.state.pa.us <http://www.depweb.state.pa.us/>  
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	P Please consider the environment before printing this email.
	 
	 
	
________________________________

	From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Sue
Dayton
	Sent: Tuesday, July 13, 2010 6:04 AM
	To: 'Al White'; 'gressitt'; 'Holcomb, Sarah, NMENV'
	Cc: pharmwaste at lists.dep.state.fl.us
	Subject: RE: [Pharmwaste] Federal Incineration Reg
	 
	Hello Al:
	 
	We are currently "fighting" two medical waste incinerators here
in NC: Stericycle and BMWNC (Healthcare Waste Solutions). Our goal is to
convince them to switch to more environmentally-friendly methods of
disposal, (i.e.), microwaving or autoclaving. Both incinerators are
located next to schools and residential neighborhoods. Both have
continued violations. Both are out of compliance with the new air
standards for air pollutants under the new EPA rules for medical waste
incinerators promulgated in 2009. Both burn paper and plastics as a
means to fuel the incinerators - a method to reduce fuel costs, but a
monstrous and absolutely needless disposal method that results in the
formation of dioxins. 
	 
	There is no regulation or testing required for the zillions of
pharmaceuticals being incinerated: we do not know what is going in nor
do we know what is going out. Haz pharms are supposed to be separated
from non-haz pharms in our state (NC does not incinerate haz waste);
however, questions remain if the two are actually being efficiently and
effectively segregated. 
	 
	The new EPA rules include (in addition to better recycling and
waste segregation, increased monitoring/testing and removal of the
exemption for uncontrolled emissions from "by-pass" events) stricter
standards for air pollutants for medical waste incinerators. We are
pushing to have our NC implement the new rules two years earlier than
the EPA's compliance date of 2014. 
	 
	Pharms disposal continues to be a wild card and must somehow be
better regulated, tested and dealt with regarding their potential
impacts to public health and the environment. 
	 
	Sue Dayton
	Blue Ridge Environmental Defense League
	North Carolina Healthy Communities Program
	PO BOX 44
	Saxapahaw, NC 27340
	(336) 525-2003
	sdayton at swcp.com
	 
	 
	 
	Our lives begin to end the day we become silent about things
that matter.   -  Martin Luther King Jr.
	 
	 
	 
	
________________________________

	From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Al White
	Sent: Tuesday, July 13, 2010 4:26 AM
	To: 'gressitt'; 'Holcomb, Sarah, NMENV'
	Cc: pharmwaste at lists.dep.state.fl.us
	Subject: RE: [Pharmwaste] Federal Incineration Reg
	 
	Sarah/ Stevan:
	 
	Incineration is a very cost intensive, non-sustainable practice,
Additionally and most importantly it must be performed properly under
strict monitoring conditions. The un-intended by-product "Dioxin" et.al.
will be produced and released If the pharm compounds are not raised to
proper temperatures and maintained for prescribed time intervals under
prescribed containment conditions. This is not a simple task. I am
amazed that this practice is even permitted.
	 
	Al White
	 
	From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of gressitt
	Sent: Monday, July 12, 2010 6:08 PM
	To: Holcomb, Sarah, NMENV
	Cc: pharmwaste at lists.dep.state.fl.us
	Subject: Re: [Pharmwaste] Federal Incineration Reg
	 
	I  would ask them to provide the reg. It is not true in Maine.
	Stevan Gressitt, M.D.
	Faculty Associate, University of Maine Center on Aging
	Founding Director
	Maine Institute for Safe Medicine
	University of New England, College of Pharmacy
	Department of Pharmaceutical Sciences 
	Associate Professor of Clinical Psychiatry
	University of New England, College of Osteopathic Medicine
	716 Stevens Avenue 
	Portland, Maine 04103
	gressitt at gmail.com 
	Cell: 207-441-0291 
	 
	
	
	---- On Mon, 12 Jul 2010 16:57:25 -0400 Sarah, NMENV Holcomb
<sarah.holcomb at state.nm.us> wrote ---- 
	Hi all - 
	Does anyone know of a federal regulation that prohibits the
incineration of controlled substances? This is information I heard this
morning, but the person I spoke with didn't have any more information
than this... 
	 
	~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
	Sarah Holcomb
	Environmental Scientist/Specialist
	Surface Water Quality Bureau
	New Mexico Environment Department
	5500 San Antonio NE, Albuquerque, NM 87109
	505-222-9587
	P  Please consider the environment before printing this e-mail 
	 
	 
	
	
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