[Pharmwaste] Items Accepted at Permanent Collection

[Fredrick L. Miller]

Burke brings up another good point.  Transportation will be an issue.
Unless LE is going to transport their collections all the way to the end
disposal facility they're going to end up using commercial transporters
at some point and at that moment the stuff becomes fully regulated with
no exceptions or exemptions.  All it takes is for a transporter to get
caught with something in the load that isn't manifested correctly for
the whole shebang to come to a screeching halt.   It is unlikely the
agencies involved have the people on staff at every location with the
education, experience, and training necessary to fully comply with 49
CFR.   It's even more unlikely they're aware of the magnitude of the
penalties involved for typical 49 CFR violations.  If they knew the
financial liability they're contemplating taking on they'd be running
away at full speed.

Fred


-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Lucy,
Burke
Sent: Monday, March 26, 2012 2:17 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Items Accepted at Permanent Collection

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