[Pharmwaste] EPA HAZARDOUS WASTE GENERATOR IMPROVEMENTS RULE

[Jeff Hollar]

All,

 

I posted the following to the LinkedIn Medical Waste Group.  I know many of
you belong to the same group so sorry for any cross postings.  I thought it
was worth posting this in both spots.

 

I recently attended a day long EPA Region VII event to learn more about this
new rule.   This new rule goes into effect May 30th in Iowa and Alaska.
Several EPA representatives spoke on various aspects of the new regulation.
I received permission would like to share with this group the presentation
slides.  Note, the presentation is specific to Iowa but it will give you a
good idea of the Federal stance.  As you are aware, states can adopt
stricter regulations.

 

I would like to share:  

 

1 - Regarding current RCRA.  The P-Listed (acute) hazardous waste
accumulation limit of less than 1 KG or 2.2 lbs/month to qualify as a CESQG
(now VSQG under new rule)is not only per month, but also cumulative.
Meaning, at any given time, a VSQG cannot have more than 2.2 lbs of acute
hazardous waste on site. 

 

2 - Regarding New Rule.  EPA Waste Code labeling of containers must
accurately reflect the contents of the waste container.  No more or less
waste codes are to be indicated on the label.  This could pose a challenge
in a pharmaceutical waste setting.  If your facility generates 15 EPA waste
codes and you come up with a label with all 15 waste codes, you need to make
sure all 15 are in the container.  It is not acceptable to use the 15 waste
code label if you only have seven waste codes in the container.  The
generator needs keep track of which waste codes are in the container and
properly reflect only those waste codes on the label prior to offering for
transportation.  

 

3 - They stress the point that under this new rule, ACCURATE hazardous waste
determinations are to be made and the domino effect of misclassifying waste
in the beginning.  I found it interesting that the EPA went after a
generator for mishandling their waste based on the fact that the generator
did not accurately classify their waste.  The generator did make waste
determinations, but they were not accurate.  Since RCRA does not indicate
waste determinations to be "accurate", EPA did not prevail.  EPA wanted to
make sure they closed this technicality in the new rule.  This now opens the
door for them to enforce inaccurate waste determinations.

 

Jeff Hollar

President

PharmWaste Technologies, Inc.

4164 NW Urbandale Dr., Ste A

Urbandale, IA 50322

515-276-5302 (general)

515-331-7310 (direct)

515-360-9785 (cell)

www.pwaste.com <http://www.pwaste.com/> 

 

 

 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20170309/27c7699d/attachment-0001.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: EPA 3-7-17.pdf
Type: application/pdf
Size: 2487170 bytes
Desc: not available
URL: <http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20170309/27c7699d/attachment-0001.pdf>