[Pharmwaste] Items Accepted at Permanent Collection

[Mark_Williams at deq.state.ms.us]

In many if not most states (ours included), the household exemption follows
the wastes through the end of life and the police station does not become
the generator of the wastes and the wastes do not lose the household
exemption. However, there are some states where HHW centers and other
facilities that handle household hazardous wastes could be regulated as a
TSD that would require a state permit.  That would be a state specific
matter that you would have to check on with the RCRA programs in your
individual state.  I believe that is the exception though and does not
apply to the majority of states.

Mark Williams, P.E., Administrator
Solid Waste Policy, Planning & Grants Branch
Mississippi Department of Environmental Quality
P.O. Box 2261
Jackson, MS 39225
Phone: 601-961-5304
Fax:      601-961-5785



From:	"Maureen Bascom" <Mbascom at harthosp.org>
To:	"ANGELA Deckers" <adeckers at cityofboise.org>,
            <pharmwaste at lists.dep.state.fl.us>
Date:	03/26/2012 02:39 PM
Subject:	Re: [Pharmwaste] Items Accepted at Permanent Collection
Sent by:	pharmwaste-bounces at lists.dep.state.fl.us



I would be interested in knowing if any unused pharma from households, that
falls under RCRA, such as P or U listed wastes are being deposited in the
police collection containers.  If so, does that now make the police
generators of hazardous wastes?

>>> "ANGELA Deckers" <adeckers at cityofboise.org> 3/26/2012 3:33 PM >>>
Greetings. I am hoping to get some feedback from other programs that have
established pharm collection containers at local law enforcement agencies.

In our program, the evidence room managers of the participating police
agencies are voicing frustration over the disposal of items in the
collection containers that are viewed, by the agencies, as outside the
realm of the intended use of the program. Examples would include vitamins,
over-the-counter meds etc...

As public works staff, I facilitated the implementation of the program,
come from the environmental side, and see the benefit of collecting some of
these products. The police staff are looking at controlling illegal use of
prescription meds. I would like them to collect these products but don't
wish to alienate them to the point that they consider backing out all
together.

Has anyone else run into this and what compromises were reached?   Where
did your program draw the line?

Please respond to adeckers at cityofboise.org

Thanks. Your time in responding is much appreciated.


Angela Deckers
Hazardous Materials Coordinator
Boise Public Works
adeckers at cityofboise.org
208.384.3983
208.433.5650 fax

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