[Pharmwaste] EPA seeking info from the Retail Industry

[Ed Gottlieb]

Thanks for the info Jeff!
 
Though this Notice of Data Availability (NODA) is open to many
industries (batteries, electronics, light bulbs, etc.) it's great that
it highlights pharmaceuticals as an example.  Once the NODA it is
published, there will be a 60 day comment period.
 
Richard Huggins, one of the EPA contacts for this docket,
[pg 5,
http://www.epa.gov/waste/hazard/generation/retl_noda_fnl_020414.pdf]
clarified that this NODA is for the Hazardous Waste Management and the
Retail Sector, Providing and Seeking Information on Practices to Enhance
Effectiveness to the RCRA Program.  This is separate from the ongoing
EPA rule making on Pharmaceutical Hazardous Waste from the Health Care
Industry.  He told me that they are coordinating with the DEA regarding
pharmaceuticals.
 
Kristin Fitzgerald, from the EPA Office of Resource Conservation and
Recovery, is one of the leads on the Pharmaceutical Hazardous Waste
effort.  She says that they are well along in the process of writing the
proposed rule.  Once published there will be a comment period for that
as well.
 
They would both very much like to get more data to improve these rules.
 Most of the data Kristin has comes from bi-annual RCRA reports from
major pharmaceutical hazardous waste generators.  There is a lack of
data from smaller generators.  She would like to have data from health
care facilities regarding:
 What medications are being managed as hazardous and which ones are
being managed as non-hazardous.
What % (and/or volume) of the hazardous medications are being flushed,
placed with red bagged medical waste, shipped out for disposal, etc.

Her contact information is:  Fitzgerald.Kristin at epa.gov
 
I'm not as clear about what data Richard would like to get.
 
If you have data that would be of use in these rule making efforts, I
urge you to submit it.
 
Two issues come to my mind that I hope will be addressed in both of
these rule makings.  I personally don't have data that can help support
these viewpoints.
 
I hope that it will be as easy as possible, within the requirements of
RCRA, for retail and health care facilities to dispose of All unwanted
pharmaceuticals, not just those listed as hazardous.  If the
requirements are a heavy burden, many waste pharmaceuticals will
continue to be unsafely, and likely illegally, disposed of.  Having to
separate out hazardous from non-hazardous is already a bit of a burden.
It is not simply a mater of checking a static list of hazardous
medications.  Some non-hazardous medications are considered hazardous
because they contain alcohol and are flammable.  Even when staff know
which are which, consistently using separate disposal containers can be
difficult.
 
The distinction between health care and household hazardous
pharmaceutical waste is not always clear.  As I learned from this
Listserv, some chemotherapy drugs, administered in health care
facilities, are extremely toxic even after being excreted by a patient
at home.  It seems to me that these wastes should be collected and
returned to the medical facility for disposal.  This would require quite
a bit of patient education, and not just rules, for implementation to be
successful.
 
Ed
 
Ed Gottlieb
Chair, Coalition for Safe Medication Disposal
Industrial Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY 14850
(607) 273-8381
fax: (607) 273-8433
>>> "Jeff Hollar" <jhollar at pwaste.com> 2/11/2014 10:22 AM >>>

EPA Consults U.S. Retailers On Hazardous Waste Management In The
Sector.  Here is the link:
http://www.waste-management-world.com/articles/2014/02/epa-consults-u-s-retailers-on-hazardous-waste-management-in-the-sector.html
 
This is an interesting article on the EPA seeking data from large
retailers regarding the management of hazardous waste, including
pharmaceuticals.  I am curious as to what they discover.
 
EPA’s pre-publication version link:
http://www.epa.gov/waste/hazard/generation/retl_noda_fnl_020414.pdf
 
Jeff Hollar

President

PharmWaste Technologies, Inc.

4164 NW Urbandale Dr., Ste A

Urbandale, IA 50322

515-276-5302 (general)

515-331-7310 (direct)
515-360-9785 (cell)

www.pwaste.com
 
 
 
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