[Pharmwaste] Items Accepted at Permanent Collection

Lucy, Burke Burke.Lucy at CalRecycle.ca.gov
Mon Mar 26 17:17:24 EDT 2012


Regardless of whether a state exempts household waste through the end of life, haulers still have to follow U.S. DOT standards.  So that's one of the benefits of using a law enforcement collection program since they have their own transport process.  The U.S. DOT does not exempt household waste from regulation if it's "consolidated shipments of household hazardous materials transported from collection centers" (CFR, Title 49, Section 171.8).  If the new DEA regulations provide more flexibility for collecting controlled substances at pharmacies, the hauling process could still be a sticking point.  

Burke 


Mr. Burke Lucy
Integrated Waste Management Specialist
Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street, PO Box 4025
Sacramento, CA 95812
Burke.Lucy at CalRecycle.ca.gov
916.341.6592

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Mark_Williams at deq.state.ms.us
Sent: Monday, March 26, 2012 12:46 PM
To: Mbascom at harthosp.org
Cc: pharmwaste-bounces at lists.dep.state.fl.us; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection

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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