[Pharmwaste] RE: guidance document

[Ed Gottlieb]

Dear Christine,

Thanks so much for sharing these excellent resources!
You are doing a great job providing leadership and guidance for all stakeholders!

Best regards,

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
________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Grossman, Christine (DEQ) [GROSSMANC at michigan.gov]
Sent: Tuesday, March 17, 2015 9:42 AM
To: Hauser, Deborah; pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: guidance document

Please see our remedy for residential drug disposal card<http://www.michigan.gov/documents/deq/deq-ess-cau-RXbrochure_279298_7.pdf> that we share and update periodically for household drugs.  We advocate that private practices and hospice make this available for reference for patients and share it at takeback events.

Our MHA Guide<http://www.michigan.gov/documents/deq/deq-p2-MHA-Guide-Rev_393335_7.pdf>, MHA Guide Example Posting<http://www.michigan.gov/documents/deq/deq-oea-mha-guideexample_396991_7.pdf>, Tutorial<http://www.michigan.gov/deq/0,4561,7-135-3585_57802_4173-285527--,00.html> and brochure<http://www.michigan.gov/documents/deq/deq-p2-MHA-Guide-Rev_393335_7.pdf> were created to assist businesses.  However this guidance only applies in Michigan given we established pharmaceutical waste as a universal waste that can be managed under streamline management standards.  More resources are also available on our healthcare web page at www.michigan.gov/deqhealthcare<http://www.michigan.gov/deqhealthcare> under Waste Health Care Resources<http://www.michigan.gov/deq/0,4561,7-135-70153_70155_3585_57802_4173-279962--,00.html> link.

Note too that EPA is expecting to initiate new rulemaking on hazardous waste pharmaceuticals<http://www.epa.gov/epawaste/hazard/generation/pharmaceuticals.htm> very soon.

Regards,

Christine Grossman, Compliance Assistance Specialist
Training and Outreach Unit, Office of Environmental Assistance, Michigan Department of Environmental Quality
Direct Phone: 517-284-6860
Environmental Assistance Center: 1-800-662-9278 or deq-assist at michigan.gov<mailto:deq-assist at michigan.gov>


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From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Hauser, Deborah
Sent: Tuesday, March 17, 2015 9:22 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] guidance document

Good morning,

Do any of you have guidance for businesses to assist them in handling/disposing their pharmaceuticals?  I’ve had this come up a number of times over the years, but I typically focus on residential.  In Ohio, residential pharms are considered household hazardous waste and therefore they can simply throw them in the trash, drop them off at a local law enforcement collection box, or take them to a pharmacy (due to the DEA rule change).  Businesses need to evaluate their waste to determine if it’s hazardous and this is something I’ve never worked on before.  My understanding is that businesses hire someone to assist with this and to assist with disposal, but I don’t actually have any experience with that.

We have this document on our website:  http://www.epa.ohio.gov/portals/32/pdf/PharmBusinessNov2010rF.pdf
This is the only guidance we provide for businesses like hospitals, vet clinics, doctor offices, etc.  In Ohio, we have an office that assists small businesses and they are interested in creating a guidance document for those types of entities.

Most of us have worked to varying extents with programs for residents to properly dispose of pharmaceuticals, but I’m wondering if we can go a step further and develop guidance for how businesses (with the focus on small businesses) actually dispose of their pharmaceuticals.

I’m hoping some of you have already done this in your state and I might avoid re-creating the wheel.  And let me know if you have had any experience with companies that provide pharmaceutical disposal assistance to businesses.  The only one I’m aware of is PharmEcology (Charlotte Smith).

Thanks,
Deb


[New Image]

Deborah Hauser
Environmental Specialist
Division of Materials and Waste Management
614.728.5353
Please note that my name has changed (previously Hoffman).  Please update your address book.




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