[Sqg-program] RE: Disposal of Pharmaceuticals in portable burn barrels - EPA's official interpretation

[Price, John L. "Jack"]

Larry: As you indicated back in February below, EPA has published an official interpretation on the use of portable burn barrels to dispose of pharmaceuticals collected in community collection events - "no."  On page 4 of the attached EPA disposal recommendations, the interpretation is that the contraband exclusion does not apply to pharmaceuticals collected at community collection events.  See section
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Jack


John L. (Jack) Price
Environmental Manager
Waste Reduction MS 4555
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL  32399-2400
Phone:850.245.8751
Fax: 850.245.8811
john.l.price at dep.state.fl.us<mailto:john.l.price at dep.state.fl.us>
www.dep.state.fl.us/waste<http://www.dep.state.fl.us/waste>
Please Note:  Florida has a very broad public records law.  Most written communications to or from state officials regarding state business are public records available to the public and media upon request.  Your e-mail is communications and may therefore be subject to public disclosure.



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From: George, Larry
Sent: Thursday, February 02, 2012 1:53 PM
To: Price, John L. "Jack"
Cc: Tenace, Laurie; Henricks, Ron; Rios, Gus; Koerner, Jeff; Stevens, Chad R.; Phillips, Cindy
Subject: RE: Disposal of Pharmaceuticals in portable burn barrels - Monroe County Sheriff's program

Jack,

I think we can all agree that pharmaceutical drug collection programs such as that being done by the Monroe County Sheriff's office are useful programs and should be promoted by DEP.  The question is how best to dispose of the drugs, once collected.

In my response to you in September 2010, I stated that "federal air regulations would not be triggered by the proposed use of a cyclonic burn barrel by law enforcement officials to dispose of pharmaceuticals collected from the public," and that we might be able to craft some kind of permitting exemption for units such as these on the state level.  As you know, we later received "unofficial" information from EPA suggesting that the exemption from federal incinerator regulations for law enforcement agencies disposing of prohibited goods may not, in fact, apply to the incineration of collected pharmaceuticals.  Since this is a matter of interpretation, EPA has promised to publish an official "applicability determination" on this issue.  Until then, we are unable to make an official determination ourselves on the use of cyclonic burn barrels by the sheriff's office, including any state permitting or exemption decision.  As soon as we know more, we will advise you accordingly.  If you wish to discuss further, please call Jeff Koerner, Administrator of the division's Office of Permitting and Compliance at 850-717-9083 (DEP 59583).

Larry George

Lawrence A. George
Division of Air Resource Management
Department of Environmental Protection
2600 Blair Stone Rd., MS 5500
Tallahassee, FL 32399-2400
Direct Line: 850-717-9021 (Receptionist: 850-717-9000; FAX: 850-717-9001)
DEP System: 59521
Please note:  Florida has a very broad public records law.  Most written communications to or from state officials regarding state business are public records available to the public and media upon request.  Your e-mail communication may therefore be subject to public disclosure.


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