[Pharmwaste] Items Accepted at Permanent Collection

[Fredrick L. Miller]

It's a slippery slope they're on.  They can maintain their HHW exemption
so long as they are fastidious about their recordkeeping and never mix
one drop/gram of non-traceable waste.  That means they can't
legitimately claim the household exemption if they allow anonymous or
unattended drop-offs.  They lose control of the process and open the
door to commercial source wastes (e.g. pharmacy/clinical) dumping.
Also, they have to be careful never to mix their own wastes with the
household wastes or they turn the whole lot into RCRA regulated
materials.

Then there's the issue of legacy and nuclear meds.  How do they keep
things like "seeds" out of their waste?  How about old stuff laden with
mercury and barium?  While the HHW exemption may apply to them as a
generator, those issues can still bite disposal facilities where the
waste is accepted and all it takes is one "oops" to kill the entire
process for one and all.  Nothing spreads in the disposal business like
the news of getting burnt and once burnt, industry reacts far more
quickly and in far more draconian fashion than regulators ever could.
They simply start saying "no" to any and all comers who look like the
party that started the problem.

In my opinion, pharmacists are the only folks out there with the
education and familiarity sufficient to get the job done.  Unfortunately
their time is usually far too precious to spend on such programs.  Until
industry, USEPA, and DEA get their act together and sing a little
harmony this problem will remain with us.

Fred Miller
USTUR
Board Member, College and University Hazardous Waste Conference


-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Maureen
Bascom
Sent: Monday, March 26, 2012 12:39 PM
To: ANGELA Deckers; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection

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?