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<P><FONT size=2>Stevan,<BR><BR>Wow! Talk about a 'loaded' question (sorry,
I couldn't resist). <BR><BR>In the case of the 151 or 191 proof liquor
analogy, the generator will likely be a conditionally exempt small quantity
generator, and therefore exempt from federal (and most local) regulations.
If the bottle contains less than 3% of it's volume by weight, it is considered
RCRA empty and can be managed as a solid waste. I can't fathom a scenario
where a bar owner would dispose of any remaining liquor seeing how there is no
shortage of people willing to drink mouthwash in order to get their alcohol
fix.<BR><BR>I'm not sure what got you worked up, or perhaps I'm missing
something, but empty liquor bottles do not fall within the hazardous waste
regulation guidelines. If what you are saying is that New Hampshire has
this requirement, I can only suggest that Florida has Cuban coffee, a tolerable
climate and real estate prices are at an all time low (although property taxes
are out of control).<BR><BR>Best Regards,<BR>Barry<BR><BR>Clean Fuels of
Florida, Inc.<BR>D. Barry Fernandez, President<BR>2635 NE 4th Avenue<BR>Pompano
Beach, FL 33064<BR>Tel: 954-791-9588<BR>Fax: 954-791-9366<BR>Toll Free:
800-725-8711<BR>barry@clean-fuels.net<BR>www.clean-fuels.net<BR><BR><BR>________________________________<BR><BR>From:
Stevan Gressitt [<A
href="mailto:gressitt@uninets.net">mailto:gressitt@uninets.net</A>]<BR>Sent:
Thursday, October 04, 2007 5:37 PM<BR>To:
pharmwaste@lists.dep.state.fl.us<BR>Subject: [Pharmwaste] Input/comment
requested on categorical classificationof hazardous waste/PPCP's and
"combustibility."<BR><BR><BR><BR>If one of the characteristics to be considered
in the disposal of hazardous waste is flammability<BR><BR>And<BR><BR>The
proposed method of “incineration” does indeed involve “burning”
explicitly<BR><BR>Then<BR><BR>Why should there not be an exemption for that
specific characteristic as a determinant of hazardous
status?<BR><BR><BR><BR><BR><BR>The situation arose in a discussion with a
non-environmental governmental more law enforcement minded type who was
interested in minimizing the disposal costs through either reverse distributors,
hazardous waste licensees, or any of the other commercial
avenues.<BR><BR><BR><BR>I am stumped.<BR><BR><BR><BR>Seems there is no reason to
apply that standard except in an almost obsessively narrow minded way to that
specific category.<BR><BR><BR><BR>I attempted to find an analogy, and without
too much caffeine and certainly below toxic espresso levels, I would ask the
following:<BR><BR><BR><BR>Some states have liquor monopolies, as in New
Hampshire. They sell Rum of 151 proof and absolute ethanol at 195 proof. They
collect a state tax on these bottles and a return fee as well. These are
flammable liquids. People get burned in restaurants from flare ups of fancy
meals known as flambe.<BR><BR><BR><BR>Empty containers that held hazardous
substances are to be considered as needing hazardous waste disposal by
“Federal?” regulation ( I saw the citation once but am not familiar with it.) as
well as some state regulations ( I have no reference here either except
hearsay.)<BR><BR><BR><BR>Hence:<BR><BR><BR><BR>1)
All restaurants that serve “flambé” should be required to dispose of their
unused liquor bottles through hazardous waste
systems?<BR><BR>2) All bars that serve over-proof
drinks and have empty containers should dispose of them through hazardous
waste?<BR><BR>3) All bottle return facilities
should either a) refuse over-proof containers or b)segregate the over-proof
containers for hazardous waste disposal<BR><BR><BR><BR><BR><BR>Besides the
lunacy of this line of reasoning, I think I must be missing
something.<BR><BR><BR><BR>Or is this another case of “unintended consequences”
which is my hunch.<BR><BR><BR><BR>Stevan Gressitt,
M.D.<BR><BR><BR><BR><BR><BR><BR><BR></FONT></P>
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