[Pharmwaste] FW: drug terminator incinerators & haz waste pharms list

Tue Nov 13 19:30:40 EST 2012

Ross, you have this one.

Drugs are chemicals and because they do not have a RCRA designation from 35
years ago does not mean they are safe to burn. Chemotherapy agents are a
great example, burning a chemical that is effective in a part per trillion
in an incinerator that burns to a part per hundred will just send it into
the air. Once again check out www.pharma-cycle.com for a reality check on
drugs in the environment.

Jim

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Bunnell, Ross
Sent: Tuesday, November 13, 2012 5:15 PM
To: 'Pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] FW: drug terminator incinerators & haz waste pharms
list

Margaret:

Do the State of Washington's hazardous waste regulations incorporate the
federal exemption for household hazardous waste?  If so, pharmaceuticals
collected from residents would be exempt from RCRA, as they are in most
other states.  That's sort of the problem.  In the absence of RCRA
applicability, there can often be a lack of meaningful regulation on
residentially-generated materials, even if they are very nasty, such as
chemotherapy agents, for example.

--Ross Bunnell

Sanitary Engineer 3

-----------------------

Connecticut Department of Energy & Environmental Protection (DEEP)

Bureau of Materials Management & Compliance Assurance

Waste Engineering & Enforcement Division

79 Elm Street

Hartford, CT 06106-5127

Office:  (860) 424-3274

Fax:       (860) 424-4059

Email:  ross.bunnell at ct.gov 

Website:  www.ct.gov/deep 

Conserving, improving and protecting our natural resources and environment;

Ensuring a clean, affordable, reliable, and sustainable energy supply.

Disclaimer:  Any views expressed in this email represent only the sender's
personal opinion based on his knowledge and experience with the DEEP, and in
no way should be considered a formal ruling by the Department.  It is always
the obligation of a generator or other handler of waste to be familiar with
and to comply with all applicable state and federal requirements.

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Shield,
Margaret
Sent: Tuesday, November 13, 2012 4:59 PM
To: Pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] drug terminator incinerators & haz waste pharms list

My view is that there is no way that they are NOT burning hazardous waste if
they are burning unsorted pharmaceuticals because there are enough commonly
used drugs that designate as RCRA waste.

Below is my standard blurb on this issue, and link to GAO report about how
the list of haz waste pharms need to be updated.  Attached is handout I use
that includes some examples of commonly used medicines that designate as
RCRA haz waste.  And then, here in Washington State, we have more stringent
dangerous waste regulations.

After RCRA was established in 1976, lists of hazardous wastes were
developed, which included chemotherapy drugs and other medicines.  About 5%
of medicines sold in 1976 were designated as hazardous waste.
Unfortunately, the RCRA lists have not been updated to consider the
thousands of new medicines, including chemotherapy drugs that have been
developed in the last thirty years.  One estimate suggests that if the RCRA
lists were updated, approximately 15% of medicines sold today would be
considered hazardous.  A recent report from the U.S. EPA's Office of the
Inspector General, titled "EPA Inaction in Identifying Hazardous Waste
Pharmaceuticals May Result in Unsafe Disposal", called on the EPA to create
a process for updating the lists and ensuring that healthcare facilities are
disposing of all waste medicines properly.

U.S. EPA Office of the Inspector General Report, May 25, 2012. EPA Inaction
in Identifying Hazardous Waste Pharmaceuticals May Result in Unsafe Disposal
<http://www.epa.gov/oig/reports/2012/20120525-12-P-0508_glance.pdf>
http://www.epa.gov/oig/reports/2012/20120525-12-P-0508_glance.pdf

Thanks for all the good resources to respond to the Drug Terminator burn
barrels.   Let's protect our law enforcement partners by ensuring they know
that this is not the way to go.

Thanks,

Margaret 

Margaret Shield PhD, Policy Liaison
Local Hazardous Waste Management Program in King County
130 Nickerson Street, Suite 100, Seattle, WA 98109-1658
(w) 206-263-3059  (c) 206-265-9732

Local Governments for Health and the Environment - www.lhwmp.org

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Bartlett,
Elizabeth
Sent: Tuesday, November 13, 2012 1:27 PM
To: 'Barry Fernandez'; Price, John L. "Jack"; 'Lucy, Burke';
Pharmwaste at lists.dep.state.fl.us
Cc: George, Larry; Perrigan, Glen
Subject: RE: [Pharmwaste] RE: pharmaceutical incineration - air permitting
exemption for portable burn units limited to "contraband"

I used to work in hazardous waste combustor permitting in a past life, so I
decided to take a quick look at the permit for this unit.

The original construction permit was issued in January 2012 for the Drug
Terminator and the MediBurn 20, but was later modified in August 2012 to
change the manufacturer/unit to the: SuperNova "ELIMINATOR", Incinerator -
Model No. SN500 - ( Small, Portable "OSWI") With this change, they added
diesel and propane as fuel sources (was originally just wood and charcoal).

OSWI = Other Solid Waste Incinerator regulated under 40 CFR 60, Subpart
EEEE.

I dug around a little bit more to see if there were any emission test
results and found the compliance page that has links to both the original
and modified permits:
<http://appprod.dep.state.fl.us/air/emission/aces/ACES_facility.asp?txtFacID
=9597>
http://appprod.dep.state.fl.us/air/emission/aces/ACES_facility.asp?txtFacID=
9597

The permit limits annual operating hours, and there is also a restriction
that the unit cannot be used to treat medical waste or hazardous waste.
Initial emissions testing must be conducted within 180 days of initial
operation with annual retesting.  They are required to test for metals,
particulate, dioxins/furans, NOx and SOx, HCl and opacity.  It is my
understanding that stack testing can be fairly expensive.

They are required to maintain records of the type and quantities of material
product burned in the unit, but I don't know how detailed the inventory
would need to be.  In reading this, I was wondering whether there was a
comprehensive list of pharmaceuticals that could assist operators in
determining/verifying that they are not burning medical or hazardous wastes.

Just some thoughts.

Elizabeth Bartlett, Engineer IV

Program & Technical Support Section

Bureau of Waste Cleanup

Florida Department of Environmental Protection

2600 Blair Stone Rd, MS 4535

Tallahassee, FL  32399-2400

850-245-7501

elizabeth.bartlett at dep.state.fl.us

Program and Technical Support website:
http://www.dep.state.fl.us/waste/categories/wc/pages/ProgramTechnicalSupport
.htm 

Interstate Technical and Regulatory Council website: itrcweb.org

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Barry
Fernandez
Sent: Tuesday, November 13, 2012 3:34 PM
To: Price, John L. "Jack"; 'Lucy, Burke'; Pharmwaste at lists.dep.state.fl.us
Cc: George, Larry; Perrigan, Glen
Subject: RE: [Pharmwaste] RE: pharmaceutical incineration - air permitting
exemption for portable burn units limited to "contraband"

Hello All:

If you go to the following link:
http://appprod.dep.state.fl.us/air/emission/apds/default.asp  and do a
search by permit no. for: 7775707-001-AC you will have the option of
downloading a Florida air permit issued for both the Drug Terminator and
it's smaller, 55-gallon cousin "MediBurn20". Basically it allows for the
portable incineration of small quantities of pharmaceuticals. I don't think
it defines what a small quantity is, nor do I think it addresses RCRA
hazardous vs non-haz. The permit in question doesn't mention any generator
limitations (i.e.: contraband from law enforcement, take-back events, etc.).
I had the opportunity to see the larger incinerator, though I did not see it
in operation. I think I have some pictures if interested.

I have no affiliation, just sharing the info. I hope it helps.

Best Regards,

Barry Fernandez, President

Clean Fuels of Florida, Inc.
2635 NE 4th Avenue
Pompano Beach, FL 33064

Office: (954) 791-9588

 <http://www.clean-fuels.net/> www.clean-fuels.net 

From: Price, John L. "Jack" [mailto:John.L.Price at dep.state.fl.us] 
Sent: Tuesday, November 13, 2012 10:26 AM
To: 'Lucy, Burke'; Pharmwaste at lists.dep.state.fl.us
Cc: George, Larry; Perrigan, Glen
Subject: [Pharmwaste] RE: pharmaceutical incineration - air permitting
exemption for portable burn units limited to "contraband"

Burke: Our RCRA group received this email and attached Determination memo
from EPA regarding the use of portable burn units for the disposal of
pharmaceuticals collected at community and other take-back collection
events.  There is a federal exemption from air permitting for these units
for destroying "contraband".  However, according to EPA, that exemption does
not apply when burning drugs from take-back events.  In Florida, it appears
that some law enforcement agencies that use these units are not aware that
the air permitting exemption is limited to contraband.  We are going to
provide this clarifying information to our law enforcement agencies.

BEGIN EPA EMAIL (note: cc list deleted)

From: Kristin Fitzgerald [mailto:Fitzgerald.Kristin at epamail.epa.gov] 
Sent: Wednesday, October 03, 2012 2:55 PM
To: Chabot, Patricia M - DNR
Cc: 
Subject: RE: Agenda Items for today's RIN Call - Pharmaceutical Burning;
Followup from MN

Here is the letter Region 6 Applicability Determination memo that Charlene
Spells mentioned on the call today. In addition to the memo I sent earlier,
this memo points out that the "contraband exemption" for law enforcement
burning drugs is only for contraband drugs and that drugs collected during
take-back events are NOT contraband. Also she suggested I include her
contact info, in case anyone wants to follow up with her:

Charlene E. Spells
U.S. EPA
OAQPS/SPPD 
RTP, NC 27711
Phone: (919) 541-5255 Fax: (919) 541-3470
spells.charlene at epa.gov

thanks,
Kristin

(See attached file: 6-30-11 AMP ADEQ EEEE Final.pdf)

**************************************************************
Kristin Fitzgerald
US EPA
Office of Resource Conservation and Recovery 
(formerly Office of Solid Waste)
mail code: 5304P
phone: 703-308-8286
fax: 703-308-0522

END EPA EMAIL

John L. (Jack) Price

Environmental Manager

Waste Reduction MS 4555

Florida Department of Environmental Protection

2600 Blair Stone Road

Tallahassee, FL  32399-2400

Phone:850.245.8751

Fax: 850.245.8811

 <mailto:john.l.price at dep.state.fl.us> john.l.price at dep.state.fl.us

 <http://www.dep.state.fl.us/waste> www.dep.state.fl.us/waste

Please Note:  Florida has a very broad public records law.  Most written
communications to or from state officials regarding state business are
public records available to the public and media upon request.  Your e-mail
is communications and may therefore be subject to public disclosure.

Please take a few minutes to share your comments on the service you received
from the department by clicking on this link DEP Customer Survey
<http://survey.dep.state.fl.us/?refemail=John.L.Price@dep.state.fl.us> .

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Lucy, Burke
Sent: Tuesday, November 13, 2012 9:37 AM
To: Pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: pharmaceutical incineration

Re: 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.

Local Charity Purchases Drug Disposal Device

http://www.wbko.com/news/headlines/Local-Charity--178122731.html

The Save Our Kids Coalition of Bowling Green has purchased a "Drug
Terminator", which will provide Kentucky State Police with a way to dispose
of the prescription medication they receive from a very successful program.

Burke

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 5:39 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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