FW: [Pharmwaste] Household definition vs prison

[William Yeman]

Thanks for the useful links Ross. 


I've always considered EPA's HHW exclusion to be "in the cards" wherever
a residence/household is present, even though it might be physically
located inside a commercial facility. 


The best examples are a hotel or apartment building: Both have
individual residences/households inside, yet the hotel or apartment
building is of course a commercial facility ineligible for the HHW
exclusion.


(Hotels are specifically listed in EPA's 261.4(b)(1) as an example of a
household.)


Bill Yeman
NYSDEC
Albany NY

>>> "Bunnell, Ross" <Ross.Bunnell at ct.gov> 03/09/13 8:55 AM >>>
p.MsoNormal {margin-left:3.0pt;} Note to self:
 
Relevant RCRA On-Line documents regarding the subject of whether or not
waste generated by prison inmates would be HHW:
 
http://yosemite.epa.gov/osw/rcra.nsf/ea6e50dc6214725285256bf00063269d/B1EA4010185041DF8525670F006C22C7/$file/12624.pdf
(hotels)
http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/4BE891214D0333658525670F006BCD54/$file/13736.pdf
(hotels #2)
http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/F99D328321A2CA5E8525670F006BE082/$file/11477.pdf
(patient waste generated in hospital rooms)
http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/36CA81A9643439BD8525670F006BDB4C/$file/11347.pdf
(wastes from offices, etc.)
 
 
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of William
Yeman
Sent: Friday, March 08, 2013 9:16 AM
To: Pharmwaste at lists.dep.state.fl.us; Jennifer (MPCA) Volkman
Subject: RE: [Pharmwaste] Household definition vs prison


 
Jennifer,

 

Do you have information on where I might find written guidance from
USEPA (e.g., one of their RCRAonLine documents) saying that they
consider HW generated from prisons to all be institutional waste?

 

thanks a lot

Bill Yeman

NYSDEC

Albany NY



>>> "Volkman, Jennifer (MPCA)" <jennifer.volkman at state.mn.us> 3/7/2013
4:47 PM >>>
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.

>>> William Yeman 3/8/2013 3:37 AM >>>
  Fred,
Instead of a hospital, do you think a closer fit would be a long-term
care facility?


 
[EPA has said that residents in long-term care facilities enjoy the
household waste exclusion (12/2/08 FR p 73525).]

Bill Yeman

NYSDEC

Albany NY


 
From: 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
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] 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] On Behalf Of Bunnell,
Ross
Sent: Thursday, March 07, 2013 2:07 PM
To: 'Pharmwaste at lists.dep.state.fl.us'
Subject: FW: [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  
Website:  www.ct.gov/deep 
 
From: 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
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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