[Pharmwaste] Scott Cassel's question

[Jim Mullowney]

Thanks Jennifer.
Agreed.
Jim Mullowney 


Sent from my T-Mobile 4G LTE Device
-------- Original message --------From: "Volkman, Jennifer (MPCA)" <jennifer.volkman at state.mn.us> Date: 6/30/16  1:10 PM  (GMT-05:00) To: "Pharmwaste, the list" <pharmwaste at lists.dep.state.fl.us> Subject: Re: [Pharmwaste] Scott Cassel's question 

I agree with what Barbara stated, for MN. 
Another consideration is that the pouches don't have enough capacity for the average person to use to get rid of what has accumulated over the years. These pouches are available for $5-7 currently at pharmacies. It is cost
 prohibitive for people to use the pouches unless they've already cleaned out and need them occasionally. So, the free part is nice and dividing it by 3 still covers a lot of people. What if they can't fit them all in? Then do they go with a mix and dispose
 that doesn't bind the pharms? Then you have the same situation we see with pharms showing up in leachate. I haven't seen leach tests on the pouches to back up claims, but maybe someone has them.



I'm not strongly opposed to this option, but just like every other, it has its downside. 



Cytotoxic drugs are a whole other level of concern and should be dealt with outside of the collection and disposal system used for all other pharms.



Medical waste incinerators are a whole other animal compared to today's Waste to Energy facilities. From permitting, to what can be put in them. They are not/should not be used for pharms, they are for biohazardous waste.





From: Pharmwaste [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Bickford, Barbara J - DNR (Barb) [Barbara.Bickford at wisconsin.gov]

Sent: Thursday, June 30, 2016 11:20 AM

To: Pharmwaste, the list

Subject: [Pharmwaste] Scott Cassel's question







Scott Cassel asked: 
Can any government officials on this list verify that their agencies approve of these pouches being landfilled?
   
 
The answer depends on who is managing the waste:  a household, a collection program or a non-household. 

 
·        
If a household disposed of the drug-in-a-pouch at home, it could be landfilled under current regulations. Although this is not the best option environmentally, Wisconsin allows
 landfilling as a last resort.
·        
If the drug-in-a-pouch ends up at a household medication collection, Wisconsin policy is that collected pharmaceutical waste must be destroyed by incineration. Other states
 might have different policies. 
·        
If a non-household, waste management regulations would apply.  Under EPA’s RCRA Subtitle C regulations (or state regulations based on them), a non-household would have to
 evaluate whether or not the “mixture” of drug + pouch materials is a hazardous waste and manage it accordingly.  If it were a hazardous waste, it could not be put in a landfill due to the Subtitle C ban on landfilling hazardous waste. Wisconsin recommends
 that all non-household pharmaceutical waste be incinerated, whether hazardous or not.

 
 
--Barb 

--------------------------------------------------------------
We are committed to service excellence.
Visit our survey at
http://dnr.wi.gov/customersurvey to evaluate how I did.
 
Barb Bickford

Medical Waste Coordinator and Hydrogeologist
Waste and Materials Mgt/Environmental Management Division

Wisconsin Department of Natural Resources

101 S. Webster St., PO Box 7921, Madison, WI 53707-7921

Phone: 608-267-3548

Fax: 608-267-2768

barbara.bickford at wisconsin.gov



 dnr.wi.gov

    
 





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