[Pharmwaste] Household definition vs prison

[Volkman, Jennifer (MPCA)]

That is an option that is pretty specific to Minnesota, just to note.

I was trying to point out that EPA views HW pharms generated from LTC's to be a business generated waste, not a HH waste. The earlier reference to an EPA publication stated that if the pharms are under the control of the resident (of a LTC, prison, hospital, etc), then they can be managed as a household waste. However, I do not know of any LTC, prison or hospitals that allow patients to have control of their pharms. The institutions store pharms at a central location and their staff distribute pharms to residents/patients, therefore, the waste is institutional waste.

The only possible exception to management other than as a HW via a HW transporter to a HW facility is if the institution is a CESQG generator. That small level of generator may have more flexibility from state to state because EPA's regulations are lighter for these small generators, hence the name "conditionally exempt". If the institutions distribute the pharms and are SQG or LQG's there is no way out of management as a HW. But remember that only a small percentage of pharms are designated to be HW and the list of what is considered hazardous also varies from state to state.
________________________________
From: Zimmer, Catherine (PSC) [Catherine.Zimmer at pscnow.com]
Sent: Friday, March 08, 2013 10:29 AM
To: Volkman, Jennifer (MPCA); Pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Household definition vs prison

Hi Jennifer and all,
Just a clarification on CESQG waste in MN.  CESQG can transport HW in their own vehicle with a bill of lading to a CESQG collection site.
Very truly yours,

Catherine Zimmer, MS, BSMT
Technical Advisor, Environmental & Healthcare
PSC Environmental Services
Ph:  713.829.6365
www.pscnow.com<http://www.pscnow.com>

Live green now!  Reduce, reuse, repair, recycle.
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Volkman, Jennifer (MPCA)
Sent: Friday, March 08, 2013 8:04 AM
To: Pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Household definition vs prison

EPA considers HW generated from prisons to be institutional waste, so we go by that. If the prison is a CESQG, disposal requirements may be less restrictive in some states (like maybe they can use HH collection kiosks for HW pharms). In MN, CESQG’s have to manage their HW just like any other larger generator--with a HW transporter to a HW facility.
From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Fred Miller
Sent: Thursday, March 07, 2013 3:38 PM
To: 'Gilliam, Allen'; Pharmwaste at lists.dep.state.fl.us<mailto:Pharmwaste at lists.dep.state.fl.us>
Subject: RE: [Pharmwaste] Household definition vs prison

To me the prison setting most closely resembles a hospital.  The cells are more akin to hospital rooms than to hotel, dorm, or bunkhouse rooms where property owners have little control over the activities of individual residents.
Fred

From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Gilliam, Allen
Sent: Thursday, March 07, 2013 1:14 PM
To: 'Pharmwaste at lists.dep.state.fl.us'
Subject: RE: [Pharmwaste] Household definition vs prison

“Considering a prison cell block to be a ‘multiple residence’ or maybe a ‘bunkhouse’, it would be reasonable to consider it to be residential household waste.   There’s no official definition, opinion, or determination to that effect, however…”
>From one of our haz waste gurus…
Allen Gilliam/ADEQ State Pretreatment Coordinator
From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Bunnell, Ross
Sent: Thursday, March 07, 2013 2:07 PM
To: 'Pharmwaste at lists.dep.state.fl.us'
Subject: FW: [Pharmwaste] Household definition vs prison
I think we would say that it’s household hazardous waste, as long as it’s generated by the inmate in his cell, and not, say, by a medical care provider in a prison infirmary or hospital.
--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<mailto:ross.bunnell at ct.gov>
Website:  www.ct.gov/deep<http://www.ct.gov/deep>

From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of William More
Sent: Thursday, March 07, 2013 2:24 PM
To: pharmwaste at lists.dep.state.fl.us<mailto:pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] Household definition vs prison

How does your state classify waste generated by a state corrections prisoner in his cell? Household Waste(like residential waste) or Institutional Waste?
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