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<P><FONT size=2>The Florida Universal Pharmaceutical Waste (UPW) rule doesn't
change any of the waste determination requirements, nor does it change DOT
shipping/segregation requirements of chemical incompatibilities. It strips
away generator requirements to track and/or report quantities of waste that
would trigger a change in generator status (SQG to LQG if generating more than
2.2 lbs of P-Listed waste, for example). The rule also increases the
accumulation time limits and eases other RCRA requirements. The mixture
rule doesn't apply here since the regs make clear that the pharms must be
individually packaged (IV, bottle, ampoule, tube, etc.). Drug co-mingling
is generally uncommon if properly done (education is key).<BR><BR>As to
segregation and the "all-in-one" packaging, so long as the materials are
chemically compatible, it should conform to RCRA and DOT. We call this
"single stream management". Whereas, rather than segregate haz from
non-haz; and segregate the haz into various RCRA classes and types, all
pharmaceuticals (with the exception of the very rare incompatibles such as
corrosives, oxidizers and reactive) combined into a single stream.
Currently, the shipping description of "Waste Medicine, liquid, flammable,
toxic, n.o.s.", for lack of a better shipping description in the HMT, seems to
be most common and applicable.<BR><BR>I've heard the argument that single-stream
management increases costs because the waste is ultimately all being treated as
RCRA once it leaves Florida. This is true if you compare dollar-for-dollar
disposal cost alone. However, considering the simplicity of a single
stream program, the waste (formulary) characterization dollars, money and
resources to label everything in inventory, the training of nursing and other
staff, labor to segregate, the level of compliance achieved, etc. it pales in
comparison when you look at the overall program budget as a whole. Say
nothing of the fact that many, many drugs not regulated under RCRA slip into
municipal landfills and wastewater treatment plants, yet pose a significant
threat to human health and the environment. The benefits to the tradeoff
are actually cheaper in the long run.<BR><BR>For those interested, here is a
link to Florida's UPW rule. It's a fairly easy read as far as regulations
go: <A
href="http://pharmtag.org/62730186.pdf">http://pharmtag.org/62730186.pdf</A><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>Cell: 305-216-4941<BR>Toll Free:
800-725-8711<BR>barry@clean-fuels.net<BR>www.clean-fuels.net<BR><BR><BR><BR>-----Original
Message-----<BR>From: Gilliam, Allen [<A
href="mailto:GILLIAM@adeq.state.ar.us">mailto:GILLIAM@adeq.state.ar.us</A>]<BR>Sent:
Wednesday, August 12, 2009 12:31 PM<BR>To: Megan Fakih;
pharmwaste@lists.dep.state.fl.us; Susan Zabo<BR>Subject: RE: [Pharmwaste]
mixtures<BR><BR>An obvious answer will probably be coming from Charlotte Smith
but, liquid wastes can fall under the criteria of haz waste,
fyi. <BR><BR>I'm not conversant on the UW rule so I don't know how all this
"mixing" may have fallen out as haz waste regs also include the "mixture
rule". 1 oz of liquid P waste mixed with a 55 gallon drum of non-haz waste
= 55+ gallons of haz waste to the best of my little haz waste
understanding. Does the UW rule for phamaceuticals bypass or supercede
this "mixture rule"? <BR><BR>§ 261.3 Definition of hazardous
waste:(2)(a)(iv) It is a mixture of solid waste and one or more hazardous wastes
listed in subpart D of this part and has not been excluded from paragraph (a)(2)
of this section under §§ 260.20 and 260.22, paragraph (g) of this section, or
paragraph (h) of this section; however, the following mixtures of solid wastes
and hazardous wastes listed in subpart D of this part are not hazardous wastes
(except by application of paragraph (a)(2)(i) or (ii) of this section) if the
generator can demonstrate that the mixture consists of wastewater the discharge
of which is subject to regulation under either section 402 or section 307(b) of
the Clean Water Act (including wastewater at facilities which have eliminated
the discharge of wastewater)..."<BR><BR>Did the UW rule dismiss the "ignitable
(I), corrosive (C) and reactive (R) haz waste" chems from this mixture
rule?<BR><BR>Allen gilliam<BR>Adeq state pretreatment
coordinator<BR><BR>-----Original Message-----<BR>From:
pharmwaste-bounces@lists.dep.state.fl.us [<A
href="mailto:pharmwaste-bounces@lists.dep.state.fl.us">mailto:pharmwaste-bounces@lists.dep.state.fl.us</A>]
On Behalf Of Megan Fakih<BR>Sent: Wednesday, August 12, 2009 10:42 AM<BR>To:
pharmwaste@lists.dep.state.fl.us; Susan Zabo<BR>Subject: Re: [Pharmwaste] (no
subject)<BR><BR><BR>Susan,<BR>I am also working to tackle our pharm waste.
In Michigan we have a Universal Waste law which I believe would allow us to
co-mingle our hazardous waste (as you described) as long as we know we aren't
putting things together that could react. The only other state that I know
has the Universal Waste law is Florida. I am not an expert on waste
labeling but it doesn't sound right that the waste is labeled as solids when you
most likely have liquids mixed in there. <BR><BR><BR><BR>Megan Fakih, RPh,
MBA<BR>St Lawrence Campus<BR>Pharmacy Supervisor<BR>1210 W Saginaw
St<BR>Lansing, Mi 48915<BR>Phone: (517) 364-6341<BR><BR><BR>>>> Susan
Zabo <SusanZ@ohanet.org> 8/12/2009 10:49 AM >>><BR>A hospital in
Ohio is investigating pharm waste. They have received a quote from a company who
currently picks up bulk chemo. The company's solution to the pharm waste is to
co-mingle all waste with the exception of bulk chemo into one container (toxic,
ignitable, corrosive) so the staff does not have to segregate into different
boxes. They then incinerate the whole drum of co-mingled hazardous waste under
NOS Waste Solids Toxic. I am uncomfortable with this practice and was wondering
if anyone has heard of this practice?<BR><BR><BR>Susan Zabo<BR>Project
Consultant<BR>Ohio Hospital Association<BR>155 East Broad Street, 15th
Floor<BR>Columbus, OH 43215<BR>614.738.2186 - Direct
Line<BR>________________________________<BR>---<BR>Note: As a courtesy to other
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