[Pharmwaste] Pills not burning in Terminator

Ed Gottlieb EGottlieb at cityofithaca.org
Thu Sep 11 12:55:19 EDT 2014


These units were designed to burn pot, not pills in plastic and foil containers.  There is no way they meet air pollution laws.  There has been discussion about them in the past on this list.  I'll cut and paste some below.

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

Tuesday, November 20, 2012 2:00 PM
Pharma phellows,

I’ve bit my tongue long enough.  Yes, I’m responsible for the EPA R6 air permitting stance on take-back pharms.

At least in AR, household haz waste loses its designation by just being household, from generation to ultimate disposal, no dispute here.

As far as the “terminator” for incineration (of contraband) see the below quote from a local chief of police who has been instrumental in making the AR take-back program such a national success (http://www.artakeback.org/ ) when asked for his opinion of take-back pharmas:

“The way I look at the drugs they are contraband. They are expired, un-used or unwanted. They serve no purpose other than to become misused, abused like the illegal drugs, which in my opinion is contraband.. K”

There needs to be a meeting of the EPA and DEA “minds” to equate the two in my opinion.  As seen on a previous post, there’s many, many LE agencies across the U.S. who are already using these cyclonic burners to incinerate drugs they’ve seized and no longer needed as evidence.

Those drugs (DEA’s “contraband”) also include an as-yet determined amount of pills harvested from medicine cabinets for pharm parties and out of the pockets of those arrested for possession of controlled pharmas not in their name.  Just don’t see the logic of pulling the LE agencies around the EPA loophole.  Their “terminators” may be spewing air pollutants out just as harmful as our take-back programs disposal procedures (exhaust fumes from all the travelling).

My objective in seeking the air division’s interpretation was to remove the other environmental footprint of transporting these pharmas from all corners of this state to a licensed TSDF (almost on the LA border) to the point at which they were gathered/incinerated under the watchful eye of LE.

Not wanting to bust our collective bubble (many have already seen this), but quoting from: Drugs and the Environment: Stewardship & Sustainability (9/12/10) by EPA’s Dr. C. Daughton, “Much of the ongoing effort in developing drug collection programs to divert leftover drugs away from sewers and trash, with the intention to protect environment - lacks a body of supporting data for justification…Hypothetically, if all disposal of medications to sewers were to cease immediately, it is possible that there might not be any measurable difference in the current environmental loadings of APIs [active pharmaceutical ingredients] in general…” http://www.epa.gov/nerlesd1/bios/daughton/APM200-2010.pdf

We may be doing more irreversible harm to the environment wasting a non-renewable energy source and spewing more global warming pollutants into the environment than we are by keeping these U/E medications out of waters of the U.S.  What’s the current estimate of pharmas actually being taken, but not being fully metabolized in our bodies passing through still causing toxicity to our aquatic life?

Allen g

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Price, John L. "Jack"
Sent: Tuesday, November 13, 2012 9:26 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<mailto: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
john.l.price at dep.state.fl.us<mailto:john.l.price at dep.state.fl.us>
www.dep.state.fl.us/waste<http://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> [mailto:pharmwaste-bounces at lists.dep.state.fl.us]<mailto:[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<mailto: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> [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<mailto:Pharmwaste at lists.dep.state.fl.us>
Cc: midwestpsc at googlegroups.com<mailto: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

8/10/2012
As a preeminent scientist with EPA in Las Vegas has stated (something to the affect), “We’re probably doing more harm to the environment via all the combustion engine emissions being discharged from individual household vehicles to the big diesel trucks’ emissions hauling the collections to a distant regulated haz waste incinerator”.

Has anyone put a pencil to that comparison to the relatively small emissions from the “terminator”?

Just another fed reg where you cannot mention common sense in the same breath without creating an oxymoron, seems to me, painted road-kill raccoons et. al.

Allen g

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, August 10, 2012 12:05 PM
To: Pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: pharmaceutical incineration

In MN, they'd have to be fully permitted according to the applicable AQ standards, SW or HW, I'm not sure of the specifics. Either way, the permitting requirements make it not feasible. Enforcement would shut them down. We're fortunate to have 10 WTE's available, including a medical waste incinerator and a few that are coal/RDF plants and half of them are approved to accept household generated pharm waste. All of them could be permitted to accept it if they choose. I should check what the longest travel distance would be, probably 2.5 hours one way. Some county law enforcement entities consolidate waste between them so that they each only have to make a trip every few years.
________________________________
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 Fredrick L. Miller [millerfl at tricity.wsu.edu]
Sent: Friday, August 10, 2012 10:56 AM
To: Pharmwaste at lists.dep.state.fl.us<mailto:Pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] RE: pharmaceutical incineration
Not in Washington.  I doubt they’d ever be able to meet pollution control and permit requirements here.  They certainly would never pass muster with our actively interested and VERY vocal citizens.

>From a regulatory standpoint, how do they fit in non-attainment areas?  What’s the mechanism for working with various airshed PCAs?  They’re combusting MSW, at best, and depending upon the source of the materials combusted, perhaps RCRA waste.  How are those hurdles overcome and the RCRA aspect controlled for?  I’m very curious as I’ve had people in states outside Washington propose similar operations and I’ve always advised against it on regulatory (pain) grounds.  If you’ve found a wrinkle in the CAA that allows for reasonable size burners that can meet all those regulatory challenges I’d be most grateful to see what you’ve got.

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]<mailto:[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<mailto:Pharmwaste at lists.dep.state.fl.us>
Cc: midwestpsc at googlegroups.com<mailto: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

________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Lotzer Donna M [DLotzer at uwhealth.org]
Sent: Thursday, September 11, 2014 12:15 PM
To: 'Jaramillo, Jeanie'; 'pharmwaste at lists.dep.state.fl.us'
Subject: RE: [Pharmwaste] Pills not burning in Terminator

What temps does that thing get up to? My guess would be the drug entity is destroyed but you may have time-release meds where there is a hard shell and the drug is inside, and when swallowed it leaches out into the gut through a membrane. The shell is usually eliminated intact in the stools, empty of any drug. In your example it may be that the shell is intact but harmless.

I saw this online: The volume of material is reduced to an average of 1% ash. Non-combustible drug paraphernalia is sterilized by heat and can be disposed in municipal waste. (The entire process appears to be rather crude and inexact.)

Just my guess…Donna

Donna Lotzer, Senior Clinical Pharmacist
Poison Education Coordinator
University of WI Hospital & Clinics Poison Prevention Center
600 Highland Avenue, MC # 9475, Madison, WI 53792
dlotzer at uwhealth.org<mailto:dlotzer at uwhealth.org>     Phone: 608-265-8160
Please encourage others to save 800-222-1222 in both cell and home phones.
This number will connect callers anywhere in the U.S. to a poison center.
Calls are free, confidential and answered 24/7/365.
Please help me educate your community about poison prevention.
Call or email me for materials or program opportunities.

From: Jaramillo, Jeanie [mailto:Jeanie.Jaramillo at ttuhsc.edu]
Sent: Wednesday, September 10, 2014 9:46 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Pills not burning in Terminator

Hello All,

Do any of you have suggestions for a group that has the Drug Terminator for med incineration, but is having trouble with "pills that are too hard to burn" with it?

Jeanie Jaramillo, PharmD
Managing Director, Texas Panhandle Poison Center
Asst. Professor, Texas Tech UHSC School of Pharmacy
1300 S. Coulter St., Suite 105
Amarillo, TX 79106
(office): (806)414-9299
(mobile): (806)376-0039

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