[Pharmwaste] Re: LTC to DEA Pharm drop off

[William More]

How is it that commercial generators can get an allowance for use of a freebie, when there are regulations in place, that have been in place, and should be considered a business expense and should be budgeted for.
 
Is DEA sponsoring an, " anybody can bring it event" or are they sponsoring a home owner cleanup event to limit the available "pharms to the street market".  LTC's should not be a source to the "pharms in the street market".  Are LTC such a source?  If so, then we should be expending some effort there.  An if they are, they should be held to meet the existing requirements for proper management through commercial disposal under the regs. and not be given a pass.
 
If we are piggybacking diversion from flushing to our Waste Water Treatment Plants and Landfills on the DEA event, then we need to look at our regulations and see if they are adequate and if not allow a general amnesty on LTC storage until the regs are fixed.
 
There are LTC generated pharms that are Hazardous Waste and even Acute Hazardous Waste. These regulations on the federal level were not enacted yesterday, but are approx 30 yrs. old.  What happens to these materials that are under a "cradle to grave" tracking when they are dumped wholesale at a DEA sponsored HHW pharm cleanup day? Is the LTC going to have a possibly required manifest for their Hazardous Waste? Are the pharms going to be adequately identified and quantified for the required records? Are we just going to give them a pass on the federal regulations?  Proper management has been mandated by the regulation for approx. 30 years and now we have a problem? What have they been doing for the 30 years? And in regards to the Acute Hazardous Waste, are the LTC's meeting the paperwork regs. that go with being a Large Quantity Generator if the they have 1Kg(2.2lbs) in total Acute Hazardous Waste (and contaminated packaging)?
 
EPA has had outreach programs to Hospitals that included proper management of pharms,  have they included LTC's?  The Hospital outreach program is ongoing and maybe LTC if they are not included could be added and there could be a organized/codified allowance for on site storage under consent until the LTC's could show that they can meet the regs.
 
 
 
 
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