[Pharmwaste] Scott Cassel's question

Thu Jun 30 13:33:26 EDT 2016

HA!!!
We're still getting in over a pound a person and I didn't say I was opposed to it, just commenting as was asked. I'm kinda bummed we don't have better pound per person data.

We are also still getting in drum quantities of DDT, pick up trucks full to the brim with paint, tons of CRTs. This is no different than any other HHW. In order to turn off the faucet you have to convince people to buy only what they need, take only what they need, prescribe only what they need, etc. Collecting and disposal is the easy part and look what a challenge it has been. Prevention of pharm waste to begin with is the tough part and I don't see anyone coming up with anything along those lines. Sometimes we wonder if we make proper disposal too easy, if people then pay less attention to what they purchase because they know where they can take the left overs.

:)
________________________________
From: DeBiasi, Deborah (DEQ) [Deborah.DeBiasi at deq.virginia.gov]
Sent: Thursday, June 30, 2016 12:24 PM
To: Volkman, Jennifer (MPCA); Pharmwaste, the list
Subject: RE: Scott Cassel's question

            I would think that after 11 national take back events, most people would have gotten rid of a lot of their unused meds.  These free pouches are a convenience, and if the contents can render drugs inactive, they will lessen the environmental risk posed by disposal.   If someone can’t fit all of their medicationsl in one of the free pouches, they can try to get another one.  Or, they could buy one one of the mailers, utilize one of the drug disposal methods involving kitty litter or coffee grounds, or just toss them in the trash (certainly not recommended but one of their options).

Deborah DeBiasi
804-698-4028
Deborah.DeBiasi at deq.virginia.gov

From: Pharmwaste [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Volkman, Jennifer (MPCA)
Sent: Thursday, June 30, 2016 1:11 PM
To: Pharmwaste, the list
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
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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<mailto:barbara.bickford at wisconsin.gov>

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