[Pharmwaste] Pharmaceutical Wastes Destruction

[Mark_Williams at deq.state.ms.us]

Hi All -

I am writing to solicit input from the list serve.  I'm on the periphery of
the regulatory world when it comes to pharmaceutical wastes and so I'm not
completely familiar with all the definitions and restrictions.  We have a
commercial infectious waste autoclave facility that has discussed with our
State Board of Pharmacy (and will assumedly discuss this with the DEA) that
they be allowed to take nonhazardous pharmaceutical wastes from state
nursing homes for "destruction".  I understood from the discussion with our
Board of Pharmacy that nursing homes (in our state) were not allowed to use
reverse distribution for expired or leftover pharmaceuticals because they
were considered dispensed.   I wondered how your states would consider such
a request and whether any of your states consider a process involving
autoclave sterilization, grinding and landfilling as appropriate
destruction? I am unclear if DEA would consider this as appropriate
destruction or not.   I've seen some information that implies that
landfilling could be an option and other information that implies it is not
an option.

Our Board of Pharmacy has asked if we have environmental rules or
restrictions that would prevent this type of "destruction" or restrictions
that prevent mixture with infectious wastes.   I know that many of your
states have state specific regulatory codes or statutes that address these
destruction issues as well as mixture with infectious wastes. Quite
honestly its difficult in reading the various emails from different states
as to what is a state specific requirement and what is a requirement of DEA
and EPA.   I would appreciate any advice you might provide on how to
respond to such a request, whether you have had experience with similar
requests and whether your state would consider this activity as a
legitimate form  of "destruction."

Thanks for your input.

Mark Williams
Solid Waste Management Programs
Mississippi Department of Environmental Quality
P.O. Box 2261
Jackson, MS 39225
Phone: 601-961-5304
Fax:      601-961-5785