<HTML><HEAD>
<META http-equiv=Content-Type content="text/html; charset=iso-8859-15">
<META content="MSHTML 6.00.2900.3640" name=GENERATOR></HEAD>
<BODY style="MARGIN: 4px 4px 1px; FONT: 10pt Tahoma">
<DIV>To all - I am posting this on behalf of a co-worker who is interested in a dialogue with other Pretreatment Coordinators prior to submitting comments to EPA.</DIV>
<DIV> </DIV>
<DIV>Please respond directly to our Pretreatment Coordinator:</DIV>
<DIV> </DIV>
<DIV>Walt Baumgartner</DIV>
<DIV><A href="mailto:wbaumgartner@cityofboise.org">wbaumgartner@cityofboise.org</A></DIV>
<DIV> </DIV>
<DIV>Thanks for your time.</DIV>
<DIV> </DIV>
<DIV>Angela Deckers</DIV>
<DIV>Hazardous Materials Coord.</DIV>
<DIV>Boise City Public Works<BR><BR>Greetings Pretreatment colleagues, <BR>Anyone out there had a chance to digest and reflect on this post Christmas package from EPA? I would hope and expect that the affected industry stakeholders will respond but the implications for PreT programs could be significant given the sheer volume of facilities as listed. Any POTWs/PreT programs intending to offer comments? Would like to hear from any/all. Any programs with established BMPs already in place? Anyone worked with their respective state health care association yet and what were the results? <BR><BR>Walt Baumgartner<BR>Pretreatment Coordinator<BR>City of Boise, Idaho<BR>208-384-3991<BR><A href="mailto:wbaumgartner%40cityofboise.org"><FONT color=#1e66ae>wbaumgartner@<WBR>cityofboise.<WBR>org</FONT></A> <BR><BR>Federal Register: December 28, 2009 (Volume 74, Number 247<BR><A href="http://edocket.access.gpo.gov/2009/E9-30625.htm"><FONT color=#1e66ae>http://edocket.<WBR>access.gpo.<WBR>gov/2009/<WBR>E9-30625.<WBR>htm</FONT></A> <BR><BR>"In particular, EPA received stakeholder comments on the issues of dental amalgam and <BR>unused pharmaceuticals management for the Health Care Industry in response to the 2007 annual review. As discussed in the final 2008 Plan EPA is again not identifying dental facilities for an effluent guidelines rulemaking in this notice at this time (September 15, 2008; 73 FR 53233). However, EPA is continuing its study of unused pharmaceutical management for the Health Care Industry."<BR><BR>"EPA estimates that it has gathered sufficient data from its site visits and outreach to begin the development of best practices for unused pharmaceutical management at health care facilities. During the next year EPA will continue to work with a variety of stakeholders in the development of these best practices and the means for their dissemination and adoption. EPA expects to complete the development of these best practices for the final 2010 Plan."<BR><BR>B. EPA Requests Comments and Information on the Following as It Relates <BR>to Unused Pharmaceutical Management for the Health Care Industry<BR><BR>[dec221] EPA solicits identification of any policies, procedures or guidelines that govern the disposal of unused pharmaceuticals from hospitals and hospices; offices of doctors and mental health practitioners; nursing, long-term care, rehabilitation, and personal care facilities; medical laboratories and diagnostic service facilities; and veterinary care facilities.<BR>[dec221] EPA solicits comment and data on: (1) The main factors that drive current disposal practices; and (2) any barriers preventing the reduction or elimination of unused pharmaceuticals to POTWs and/or surface waters. In particular, EPA solicits comment on the extent to which that the Controlled Substances Act (21 U.S.C. 801 et. seq.) <BR>complicates the design of an efficacious solution to drug disposal. <BR>[dec221] EPA solicits quantitative information or tracking sheets for the past year on the disposal of unused pharmaceuticals via the toilet, drain, or sewer.<BR>[dec221] EPA solicits data on how control authorities are currently controlling disposal of unused pharmaceuticals via wastewater.<BR>[dec221] EPA solicits information on any technologies or BMPs that are available to control, reduce, or eliminate the disposal of unused pharmaceuticals to POTWs.<BR>[dec221] EPA solicits qualitative and quantitative data on the effectiveness and annualized costs of the technologies or BMPs that health service facilities use to control or eliminate the discharge of unused pharmaceuticals from their wastewater. EPA is also interested in <BR>obtaining information on the current costs (including labor) associated with disposal of unused pharmaceuticals via the drain or toilet.<BR>[dec221] EPA solicits any studies or information on the potential for unused pharmaceuticals that are disposed of in non-hazardous-<WBR>waste landfills to contaminate underground resources of drinking water.<BR></DIV></BODY></HTML>