[Pharmwaste] Household definition vs prison

Gonzalez - CDPHE, Lillian lillian.gonzalez at state.co.us
Mon Mar 11 12:34:16 EDT 2013


Colorado's assessment of waste from LTCs is the same as Minnesota's-we
consider the waste to be generated by a business and thus fully subject to
RCRA requirements.  We too have found that LTC residents almost never have
control of their own meds and furthermore, LTC licensing requirements in
Colorado *require* the LTC to maintain strict control of the medications
from the dispensing all the way through disposal.  The residents have no
control or knowledge regarding how their meds are disposed.

Last week Colorado sent out the attached flier to every licensed nursing
home in the state.  Currently, most nursing homes in Colorado are disposing
of their waste meds (RCRA and non RCRA hazardous) in the trash, down the
drain or in the sharps container.  This flier is the cornerstone of our
initiative to change this current disposal practice by September 1 of 2013.


Based on drug disposal logs, our initial estimate is that nursing homes in
Colorado generate 24,000 - 67,000 lbs of medication waste per year.  We
plan to gather additional data to determine the accuracy of that estimate.

I would be interested to know how/whether other states are working with
LTCs.

-- 
Lillian Gonzalez, Health Care Sector Lead
Hazardous Waste Compliance Assurance Unit
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO  80246-1530
303.692.3351

See our resources regarding medical and pharmaceutical wastes at:
www.colorado.gov/cdphe/medicalwaste


On Fri, Mar 8, 2013 at 11:30 AM, Volkman, Jennifer (MPCA) <
jennifer.volkman at state.mn.us> wrote:

>  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
>
>
>
> *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<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<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<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
>
> *Website*:  www.ct.gov/deep
>
>
>
> *From:* pharmwaste-bounces at lists.dep.state.fl.us [
> mailto:pharmwaste-bounces at lists.dep.state.fl.us<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?
>
> ---
> Note: As a courtesy to other listserv subscribers, please post messages to
> the listserv in plain text format to avoid the garbling of messages
> received by digest recipients.
> ---
> TO SUBSCRIBE, go to:
> http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
> TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to
> pharmwaste-unsubscribe at lists.dep.state.fl.us -- the subject line and body
> of the e-mail should be blank.
> If you believe you may be subscribed with a different email address,
> please visit the subscriber listing at
> http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste
> FOR PROBLEMS:  Contact List Administrator Laurie.Tenace at dep.state.fl.us
> SEND MAIL to the list server at:  pharmwaste at lists.dep.state.fl.us
>
>


-- 
Lillian Gonzalez, Health Care Sector Lead
Hazardous Waste Compliance Assurance Unit
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO  80246-1530
303.692.3351

See our resources regarding medical and pharmaceutical wastes at:
www.colorado.gov/cdphe/medicalwaste
-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20130311/e4e424cf/attachment.htm
-------------- next part --------------
A non-text attachment was scrubbed...
Name: Nursing Home Flyer-FINAL 2-5-13.pdf
Type: application/pdf
Size: 2278790 bytes
Desc: not available
Url : http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20130311/e4e424cf/NursingHomeFlyer-FINAL2-5-13-0001.pdf


More information about the Pharmwaste mailing list