[Pharmwaste] RE: pharmaceutical incineration

[Gilliam, Allen]

I tried a similar approach for Arkansas' take back (http://www.artakeback.org/ ) approach and got brick walled because EPA's definition of contraband did not meet the DEA's.  One of our own agency's air division's gurus indicated if the take-back produce was received by law enforcement, they could take it out to the animal shelter's incinerator for disposal along with the euthanized.

Cut and pasted from past correspondence from our R6 air division contact:
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From: Aisling.Kathleen at epamail.epa.gov [mailto:Aisling.Kathleen at epamail.epa.gov]
Sent: Wednesday, May 11, 2011 1:27 PM
To: Bassett, Karen (Deputy Director, ADEQ)
Cc: Welton.Patricia at epamail.epa.gov; Thompson.Steve at epamail.epa.gov; Herrera.Esteban at epamail.epa.gov
Subject: Re: Fw: Help on a Regulatory Interpretation-60 CFR Subpart EEEE

Karen, I wanted to follow up on our call yesterday.  When we spoke, I asked who the owner of the incinerator was and you said that it was the local sheriff's office. I said that the incinerator then met one half of the exemption given in 40 CFR 60.2887(p), which is that the incineration unit is operated by a government agency.  At that time, I was waiting on an interpretation from EPA Headquarters on the second half of the exemption.

I received HQ's interpretation today, and it is that drugs accepted during a drug takeback program do not meet the regulatory exemption given for contraband or prohibited goods because they are neither contraband nor prohibited (one of our lead local Chiefs of Police vehemently disagreed).  Pharmaceutical drugs collected during these programs must be sent to a properly permitted and operated municipal waste incinerator.

I left you a phone message about an hour ago, but I wanted to get this information to you so you can pass it on to the counties involved.  In this case, their incinerators ARE NOT exempt from 40 CFR Subpart EEEE regulations for other Solid Waste Incineration Units.  If the State of Arkansas would like an applicability determination letter on this matter, please contact me.

Kathleen Aisling
Environmental Engineer
Air Enforcement Section
US EPA, Region  6, 6EN-AA
1445 Ross Avenue
Dallas, TX  75202-2733
Phone:  214.665.6406
Fax:  214.665.3177
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As you know these units are the size of 55 gallon drums and ARE currently used by many local law enforcement agencies across the nation for disposal of confiscated drugs after a bust anyway.  I'm not hearing of any public outcries for this practice.  I just don't see the difference except as one pharmwastelistserve subscriber indicated she thought some of the exhaust may contain even further toxic air emissions (dioxins?).  Is it possible a meth lab's incinerated chems and end product could be less toxic than OTC/prescribed drugs?

Allen g

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Hoffman, Deb
Sent: Friday, August 10, 2012 7:39 AM
To: Pharmwaste at lists.dep.state.fl.us
Cc: midwestpsc at googlegroups.com
Subject: [Pharmwaste] pharmaceutical incineration

Greetings,

Here in Ohio, we're discussing the usage of the portable incinerators, from an air pollution standpoint.  I've been working with a colleague in the Ohio EPA Division of Air Pollution Control.  I'd like to know if anyone is aware of any recent research on the effectiveness of portable incinerators, or if they are being used in other states.  And if you would like to share incineration options in your state, I would be interested in hearing them.

Thank you,
Deb


Deb Hoffman
Environmental Specialist
Division of Materials and Waste Management
Ohio EPA
614.728.5353


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