[Pharmwaste] NERC Guidance Documents

Tenace, Laurie Laurie.Tenace at dep.state.fl.us
Wed Sep 27 09:51:16 EDT 2006

These guidance documents are now available from NERC - Laurie



1. Managing Unwanted Medications - 2 Guidance Documents Now Available

Based on two years of research and eight pilot collections, NERC has
published the most comprehensive guidance for operating legal and safe
unwanted medication collections that is available.   


Two guidance documents have been published: one that is general and addresses
any type of unwanted medication collection, and the other is specific to
collections held in conjunction with household hazardous waste events.


Operating Unwanted Medication Collections - A Legal & Safe Approach
[http://www.nerc.org/adobe/setting.up.draftFINAL.pdf], was researched and
written with funding from an EPA grant.  


Holding an Unwanted Medication Collection as Part of a Household Hazardous
Waste Event - A Legal & Safe Approach
[http://www.nerc.org/adobe/hhw.setting.upFINAL.pdf] was researched and
written with funding from a USDA-Rural Utilities Service grant. 


These documents carefully lay out the federal and state legal requirements
for operating an unwanted medication collection, as well as providing
in-depth information about planning and implementation such events.  Data
from the pilot collections is reported, including costs, hours to plan and
implement the collection events, and the amount of material that was


For more information, contact Lynn Rubinstein [lynn at nerc.org].


2. Cleaning Out Bulk Compounding Chemicals from Pharmacies - Guidance

Pharmacies may have stores of unwanted chemicals that were once used in the
on-site preparation of prescriptions.  Known as "bulk compounding chemicals,"
these often include coal tar, phenol, and sulfur power. Most pharmacies
rarely, if ever, do on-site compounding of pharmaceuticals anymore.


Bulk compounding chemicals are chemicals - not drugs.  Once determined to be
a waste rather than an inventory item, many of these are Resource
Conservation Recovery Act (RCRA) hazardous wastes.  Due to a lack of
familiarity with how to dispose of these chemicals, as well as the difficulty
and expense of disposing of small amounts of wastes (i.e., one or two
gallons) on a one-time basis, pharmacies may store unwanted bulk compounding
chemicals in a cabinet for many years, uncertain of what else to do.  


Providing the opportunity to appropriately remove and manage these materials
is a valuable service that household hazardous waste programs can offer to
businesses in their community. The goal is to divert bulk compounding
chemicals from the municipal solid waste stream by establishing a cost
effective and convenient system for disposal as a hazardous waste. The
strategy is to create partnerships between existing household hazardous waste
programs that accept materials from conditionally exempt generators of
hazardous waste.


Cleaning Out Bulk Compounding Chemicals from Pharmacies: Developing
Partnerships with Household Hazardous Waste Programs
is a new guidance document that details how to develop successful
partnerships between household hazardous waste collection programs and
pharmacies.  The guidance is the result of a pilot project that NERC
conducted, with funding from the EPA.  The project identified pharmacies with
unwanted bulk compounding chemicals and demonstrated that their participation
in local household hazardous waste collections is a cost-effective and
convenient method of disposing of these materials responsibility.  This
document does not address the disposal of unwanted medications.  


For more information, contact Lynn Rubinstein [lynn at nerc.org].




Lynn Rubinstein, Executive Director
Northeast Recycling Council, Inc.
139 Main St., Suite 401
Brattleboro, VT  05301
lynn at nerc.org    www.nerc.org
802-254-3636/802-254-5870 fax

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