[Pharmwaste] Federal RegisterApril 30th

Charlotte A. Smith csmith at pharmecology.com
Wed May 2 09:05:43 EDT 2007


One of the concerns with using reverse distributors involves hospital
generated waste, which includes chemotherapy IVs and other potentially
hazardous drugs from an OSHA perspective. Reverse distributors are
required by FDA and State Boards of Pharmacy to inventory all items
received in their warehouse. I am very concerned about worker exposure
not only to hazardous drugs but also to any infectious waste that might
inadvertently be disposed in that waste stream. This should not be an
issue on the consumer side, unless, of course, patients receiving
chemotherapy IVs at home would send partial IVs, etc. to the RDs. I
think all scenarios need to be carefully examined. 

 

Charlotte A. Smith, R. Ph., M.S., HEM

President

PharmEcology Associates, LLC

200 S. Executive Drive, Suite 101

Brookfield, WI 53005

262-814-2635

Cell 414-915-4026

Fax 414-479-9941

csmith at pharmecology.com

www.pharmecology.com

H2E Champion for Change Award Winner

________________________________

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Latham,
Mark
Sent: Wednesday, May 02, 2007 7:53 AM
To: Lucy Doroshko; pharmwaste at lists.dep.state.fl.us; gressitt
Cc: Bunnell, Ross; Sullivan, Kevin T
Subject: RE: [Pharmwaste] Federal RegisterApril 30th

 

Thanks, Steve, this is an encouraging development on the federal level! 

 

Although the state of Connecticut has not included pharmaceutical waste
to our universal waste rules, we plan to explore this option in the
future. Our universal waste rules currently include used electronics for
example. I can see that this option would promote the proper and safe
management of hazardous consumer products with some streamlined
requirements and possibly promote recycling-it has been our experience
that virtually all returned drugs are disposed not recycled. I'm not
sure if I agree with not considering a waste a waste until the
redistribution center makes the determination. As a universal waste, it
seems to me that the waste would be declared a waste by the generator,
rightfully so!

 

Lucy, I would like to contact you (Fla. and any other state) about the
strengths of your program and any challenges you face if any by
implementing this waste stream as a universal waste. 

 

Best Regards,
Mark

Mark Latham
Environmental Analyst 2
Waste Engineering & Enforcement Division

Department of Environmental Protection
79 Elm Street
Hartford, CT 06106

tele: (860) 418-5930, x2170
fax: (860) 424-4059

________________________________

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Lucy
Doroshko
Sent: Wednesday, May 02, 2007 8:18 AM
To: pharmwaste at lists.dep.state.fl.us; gressitt
Subject: Re: [Pharmwaste] Federal RegisterApril 30th

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
517/373-1322
FAX:  517/241-0858
doroshkl at michigan.gov

 

Check the DEQ Recycling Website at www.michigan.gov/deqrecycling


>>> "gressitt" <gressitt at uninets.net> 5/1/2007 10:22 PM >>>

See item 2990 Universal waste and pharmaceutical products

 

Stevan Gressitt, M.D.

207-441-0291

 

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