[Pharmwaste] Federal RegisterApril 30th

Volkman, Jennifer Jennifer.Volkman at state.mn.us
Mon Jun 25 19:39:03 EDT 2007

I don't know if you received a reply yet.  Here is a shot: 
In order for a waste to be a Universal Waste, it first has to be a RCRA
hazardous waste.  The UWR relaxes RCRA standards to theoretically
promote the proper management and recycling of certain hazardous waste
streams.  The RCRA was originally designed to regulate large industrial
chemical generators, so the regulations are pretty heavy.  It's been 25
years, they are due for an overhaul, but we got the UWR instead, which
is ok.  So far, the federal UWR includes: fl lamps, mercury containing
devices, pesticides and certain batteries.
Some pharms are RCRA hazardous, some are not, so the only pharms covered
would be those that are hazardous.  This is why some pharms, the non-haz
ones, can still be sewered.  Household programs that collect pharms
generally ship them all as HW for incineration because that is the best
management option for disposal.  There are also combinations of
radioactive and infectious haz and non-haz pharms.
The Federal RCRA and UWR apply to commercial/industrial generators, but
some states have rules that bring household generated waste into RCRA
when they are collected or generated.  In that case, state's HHW rules
and/or the UWR can apply to collection and management.  
Including pharms in a state's UWR would theoretically make it easier to
manage pharms, but the larger barrier of DEA and Pharmacy Board
regulations is still there.

	-----Original Message-----
	From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of rachel
	Sent: Thursday, June 21, 2007 3:46 PM
	To: Lucy Doroshko
	Cc: pharmwaste at lists.dep.state.fl.us; gressitt
	Subject: Re: [Pharmwaste] Federal RegisterApril 30th
	I have a question that I feel is probably a stupid one, but I'm
asking anyway because I don't know waste terminology as well as you
folks.  If pharm waste is perhaps going to be added into the universal
waste rules, what is it classified as right now?  Does this include
household pharm waste, or just commercial/industrial?
	Lucy Doroshko wrote: 

		Michigan has already included pharmaceutical waste in
their universal waste rules.  Any other state do that?
		Lucy Doroshko, Recycling Specialist
		Pollution Prevention and Compliance Assistance Section
		MDEQ Environmental Science and Services Division
		525 W. Allegan, One North
		PO Box 30457
		Lansing, MI  48909-7957
		FAX:  517/241-0858
		doroshkl at michigan.gov
		Check the DEQ Recycling Website at
		>>> "gressitt" <gressitt at uninets.net>
<mailto:gressitt at uninets.net>  5/1/2007 10:22 PM >>>

		See item 2990 Universal waste and pharmaceutical


		Stevan Gressitt, M.D.




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	rachel.golden at ncmail.net
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