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<TITLE>DOT Regulations on Pharm Waste?</TITLE>
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<P><FONT SIZE=2 FACE="Arial">Good Morning -</FONT>
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<P><FONT SIZE=2 FACE="Arial">The Washington State Department of Ecology has put together a team to build a policy on pharmwaste that achieves as much regulatory harmony as possible and to be applied to the regulated community. Does anyone have any experience working with the U.S. Department of Transportation with regards to the transportation of mixed bins of waste drugs?</FONT></P>
<P><FONT SIZE=2 FACE="Arial">The Florida Department of Environmental Protection advises the "ORM-D" placard on its pharmaceutical fact sheets. Our department's household take-back pilot will be using "ORM-D" as well, under instructions from a hazardous waste hauler. I have also seen Class 6.1 Medicine: liquid, toxic, n.o.s. and Medicine: solid, toxic, n.o.s. We are looking to ship a mixed bin of p-listed, u-listed, state-designating, pills, patches, IV's, inhalers, maybe regulated medical plus pharmaceutical, maybe controlled substances, and otherwise waste drugs. We are wondering if anyone has asked for and received a fax-back or clarification of some kind on what the DOT requires for drug waste transportation.</FONT></P>
<P><FONT SIZE=2 FACE="Arial">The EPA/DOT joint uniform manifest changed in September 2006 and now requires up to six waste codes. We are pushing for as little shipping regulations as necessary for reasonable transporter safety so that clinics can throw waste into one bin. We generally believe that a "consumer commodity" or "miscellaneous" label is justified for pharm waste since most substances are inert, frequently transported safely, and individually packaged. We also understand that when negotiating with national organizations (like the DEA), often what we think is reasonable doesn't mean squat.</FONT></P>
<P><FONT SIZE=2 FACE="Arial">Anyone been down this road before?</FONT>
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<P><FONT SIZE=2 FACE="Arial">Thanks for your time,</FONT>
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<P><FONT SIZE=2 FACE="Arial">Mark Beres</FONT>
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<P><FONT SIZE=2 FACE="Arial">Washington State Department of Ecology</FONT>
<BR><FONT SIZE=2 FACE="Arial">Hazardous Waste and Toxics Reduction</FONT>
<BR><FONT SIZE=2 FACE="Arial">425.649.7065</FONT>
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