[Pharmwaste] Re: Pharmwaste Digest, Vol 20, Issue 17

Andy Kubalak andy.kubalak at epa.state.oh.us
Wed Jun 27 13:12:36 EDT 2007

Andy Kubalak wrote:

Ohio EPA, Division of Hazardous Waste Management responds to your
question about regulating pharmwaste/hazardous waste in Ohio.  Medical
waste may sometimes be infectious waste; hazardous waste, or both
hazardous waste and infectious waste (mixed waste).  Consider the
following possible waste management scenarios where waste is generated
by the home health care provider at the patients home:

A. 	Medical waste, characterized only as infectious waste must be
removed by the health care provider and must be managed under the health
care provider’s infectious waste generator status.  The rules for
small and large generators of infectious waste are found at Ohio
Administrative code (OAC) rule 3745-27-30 which are standards for
generators of infectious waste and OAC rule 3745-27-35 which are
standards for handling infectious waste.  

	Home health care providers are allowed to transport infectious
waste from the individual’s home back to the home office, without
being a registered transporter even if they work for a large generator. 
This is an interpretation we draw from OAC rule 3745-27-31(A)(4).  An
emergency medical services organization, as defined in section 4765.01
of the Ohio Revised Code, that transports infectious waste that is
generated in providing care to a patient by that emergency medical
services organization.  

B. 	Medical waste, that is mixed infectious and hazardous waste must
be managed under the hazardous waste rules. Under OAC rule
3745-27-30(C)(7) any infectious waste mixture that meets the definition
of hazardous waste as specified in rule 3745-51-03 of the OAC shall be
managed as hazardous waste in accordance with Chapters 3745-50 to
3745-69 of the Administrative code.  So if the mixed waste is a
household hazardous waste it is exempt from regulation as a hazardous
waste and can be thrown into the trash.  

	The hazardous waste rules allow this waste to be disposed in the
patients trash. 

	Additionally, if the health care provider directs someone in the
home to administer the medication, the waste may also be disposed in the
patients trash.  Hopefully the health care provider will advise of the
best management practices when these materials are to be disposed in the
patients trash.  

>>> <pharmwaste-request at lists.dep.state.fl.us> 6/26/2007 8:41 PM >>>
Send Pharmwaste mailing list submissions to
	pharmwaste at lists.dep.state.fl.us 

To subscribe or unsubscribe via the World Wide Web, visit

or, via email, send a message with subject or body 'help' to
	pharmwaste-request at lists.dep.state.fl.us 

You can reach the person managing the list at
	pharmwaste-owner at lists.dep.state.fl.us 

When replying, please edit your Subject line so it is more specific
than "Re: Contents of Pharmwaste digest..."

Today's Topics:

   1. Not pharmawaste - euro traffic pollutant study (Bill Lewry)
   2. RE: Federal RegisterApril 30th (Volkman, Jennifer)
   3. Richard Basore/Kdhe is out of the office.
      (RBasore at Kdhe.state.ks.us)
   4. 2007 Northeast Water Science Forum - PPCPs: State of	the
      Science - Registration & Hotel Reservation Deadline Approaching!
      (Marianna Vulli)


Message: 1
Date: Mon, 25 Jun 2007 12:13:21 -0500
From: Bill Lewry <Bill_Lewry at kcmo.org>
Subject: [Pharmwaste] Not pharmawaste - euro traffic pollutant study
To: pharmwaste at lists.dep.state.fl.us 
	<OF1808B694.D7A23C8B-ON86257305.005E67CF-86257305.005E7BDA at kcmo.org>
Content-Type: text/plain; charset="us-ascii"


If I offend anyone with this cross posting - I apologize - but felt it
worthwhile from the health perspective
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Message: 2
Date: Mon, 25 Jun 2007 18:39:03 -0500
From: "Volkman, Jennifer" <Jennifer.Volkman at state.mn.us>
Subject: RE: [Pharmwaste] Federal RegisterApril 30th
To: "rachel golden" <rachel.golden at ncmail.net>,	"Lucy Doroshko"
	<doroshkl at michigan.gov>
Cc: pharmwaste at lists.dep.state.fl.us, gressitt <gressitt at uninets.net>
	<6246727221874A4FB8D3F9BBC37D9BD5020D2550 at s-sp22.pca.state.mn.us>
Content-Type: text/plain; charset="us-ascii"

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
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
chemical generators, so the regulations are pretty heavy.  It's been
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
would be those that are hazardous.  This is why some pharms, the
ones, can still be sewered.  Household programs that collect pharms
generally ship them all as HW for incineration because that is the
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,
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
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.




		Pharmwaste mailing list
		Pharmwaste at lists.dep.state.fl.us 

	Rachel Golden
	Adult Environmental Education Program Manager
	Office of Environmental Education
	NC Department of Environment and Natural Resources
	1609 Mail Service Center, Raleigh, NC 27699-1609
	919-733-0711 (phone) 919-733-1616 (fax)
	rachel.golden at ncmail.net 
	Check out the EcoSmart Consumer MySpace page
<http://www.myspace.com/ecosmartconsumer>  and blog
<http://ecosmartconsumer.blogspot.com/> !

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Message: 3
Date: Tue, 26 Jun 2007 06:16:46 -0500
From: RBasore at Kdhe.state.ks.us 
Subject: [Pharmwaste] Richard Basore/Kdhe is out of the office.
To: pharmwaste at lists.dep.state.fl.us 
	<OF12E8AAFA.6B1542E0-ON86257306.003DF61B-86257306.003DF61B at kdhe.state.ks.us>
Content-Type: text/plain; charset=US-ASCII

I will be out of the office starting  06/22/2007 and will not return

I will respond to your message when I return. If you need immediate
assistance  concerning the LEP program please contact Scott
in Topeka. If you need assistance for an environmental issue in the SC
district please contact John Goetz.


Message: 4
Date: Tue, 26 Jun 2007 13:39:08 -0400
From: "Marianna Vulli" <mvulli at neiwpcc.org>
Subject: [Pharmwaste] 2007 Northeast Water Science Forum - PPCPs:
	State of	the Science - Registration & Hotel Reservation
To: <pharmwaste at lists.dep.state.fl.us>
	<D85AC7B6452C8B41979CF91FE5DEB7C6ABC129 at neimail.NEIWPCC.local>
Content-Type: text/plain; charset="us-ascii"

2007 Northeast Water Science Forum

Pharmaceuticals and Personal Care Products: State of the Science


August 8th & 9th


Holiday Inn By the Bay

Portland, Maine


Register and Make Your Hotel Reservations Before July 7th!



Register before July 7th to take advantage of the early-bird
registration fee and to secure the special group rate at the Holiday
By the Bay.  


To view the conference agenda and to register online please visit


Please contact the Holiday Inn By the Bay
directly at (800) 345-5050 to make your reservations.  Reference the
"2007 Northeast Water Science Forum" when making your reservation to
receive the group rate of $120.  The room block expires July 7th!


For more information, please contact Marianna Vulli at
mvulli at neiwpcc.org or (978) 323-7929 x256.  


Thank you and see you there!


Conference sponsored by: 

New England Interstate Water Pollution Control Commission (NEIWPCC)




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