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<DIV>This would seem to call for a "baseline assessment" of the industry's handling practices, so that we can look at "take back" efforts with more informed vision.</DIV>
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<DIV>I would add that we would need the same assessment for:</DIV>
<DIV>-long term care facilities</DIV>
<DIV>-Skilled nursing/rehabilitation facilities</DIV>
<DIV>-mental heath facilities</DIV>
<DIV>-Medical Clinics </DIV>
<DIV>-retirement complexes with medial clinics</DIV>
<DIV>-veterinary hospital/kennels</DIV>
<DIV>-veterinary services for agricultural purposes -livestock/ feed lot/dairy</DIV>
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<DIV>There may be others.</DIV>
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<DIV>
<DIV>Matt McCarron</DIV>
<DIV>Pollution Prevention/Green Business</DIV>
<DIV>CA Dept. of Toxic Substances Control</DIV>
<DIV>700 Heinz Ave. Suite 300 MS R2 - 2-3</DIV>
<DIV>Berkeley, CA 94710</DIV>
<DIV> </DIV>
<DIV>510-540-3828</DIV>
<DIV> </DIV>
<DIV>Sustaining our resources sustains our future generations</DIV><BR><BR>>>> "William More" <wamore@gw.dec.state.ny.us> 6/22/2009 7:57 AM >>><BR></DIV>
<DIV>So what <U>is</U> the present compliance rate with our Hospitals Pharmacies with the RCRA - Hazardous waste regulations? </DIV>
<DIV>How are they achieving Hazardous Waste Determinations? How do they segregate wastes, and when?</DIV>
<DIV>How many have a program that know where the stuff that the reverse distributors don't want to take go? What happens to the waste - contaminated packaging - that comes from dispensing drugs that can be a "P" waste? Do the reverse distributors(RDs) tell the hospitals about these materials? Do they, the RDs, take these back?</DIV>
<DIV>Does that make them a TSDF? Are they manifested? What mechanisms are the Hospital Pharmacies using to recover these materials from the patient floors?</DIV>
<DIV>What are the RDs doing with those materials that are never credited? The partials that can't be reused because that are not factory sealed? Those materials that are <U>so</U> far out of date? The RDs know what they are. Do they pick them up anyway. Does that make them a TSDF? Are they manifested?</DIV>
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<DIV>Have all of the Hospital Pharmacies had their Formulary,(likely stocked Drugs), reviewed as to which ones can be a Hazardous Waste when unusable ,unreturnable, un credited, when a waste. Have they looked for characteristic Hazardous Waste? Mercury compounds that may be used as a preservative? Metals in vitamins or dietary supplements? Alcohol or CFCs in inhalers?</DIV>
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<DIV>What are we seeing when we look at these questions???????</DIV>
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