[Pharmwaste] Question from WA Dept. of Ecology: Permit exemption language for pharms collection

Vivian Futran Fuhrman vivian at productstewardship.us
Fri Jun 9 14:52:58 EDT 2017


Hi All,

I am passing on a question from Megan Warfield at the WA Department of Ecology as I think this group might be able to shed some light:

Washington state solid waste law allows the Department of Ecology to provide, through regulation, exemptions from solid waste permitting for facilities/activities that meet certain conditions.

There are several police/sheriff departments across the state that conduct pharmaceutical collection from residents.  Technically, they are required to obtain solid waste permits because they (and the activity) are not exempt in the current regulation.

In Washington local health departments are the issuing authority for solid waste permits.  Most health departments simply "turn a blind eye" to this activity.  Who wants to tell their local police chief he has to get a solid waste permit for offering this valuable public service?

To date, there haven't been any issues.  But our solid waste regulation is open for revision right now and I would like to craft language to solidify an exemption for pharmaceutical collection  - especially since the DEA regulation authorizes collection in several locations beyond law enforcement (pharmacies, etc.).   I'd like to add something along the lines of, "if the activity is compliant with DEA regulations and other pertinent laws and regulations, the activity is exempt from solid waste permitting."  Sounds simple, but coming up with the specific language within the framework of our existing solid waste regulation has proven difficult.

Has anyone dealt with this permitting issue already?  If so, please contact Megan Warfield:

Megan Warfield
MRW Coordinator
Dept. of Ecology
(360) 407-6963
Meth461 at ecy.wa.gov<mailto:Meth461 at ecy.wa.gov>

Best,
Vivian
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Vivian Fuhrman, Ph.D.
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Product Stewardship Institute, Inc.
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