[Pharmwaste] Drug Terminator

Fredrick L. Miller millerfl at tricity.wsu.edu
Tue Jun 19 13:20:58 EDT 2012


After checking the company's web site I can't determine if they've done the engineering necessary to determine their unit is CAA exempt.  It's a virtual certainty they won't pass muster in many non-attainment areas covered by the more restrictive APCAs.  I am especially concerned about police departments' ability to resist the urge to burn things they shouldn't from clandestine labs.  Another danger is their being "good neighbors" when helping out with events such as HHW/take back programs where they're also likely to drop something they shouldn't into the hopper.

There is no end to the parade of vendors with "good ideas" selling magic cure-all devices to our law enforcement and emergency response agencies.  They specialize in taking advantage of the macho "we're the guys with the guns and big shiny trucks" mentality that prevails, along with the flowing grant money from multiple sources which comes without competent adult supervision or any clue about regulatory requirements outside their narrow field of vision.  If I sound bitter it's because I've seen so many dollars wasted on so many of these trinkets now sitting in stations around the country gathering dust...or worse.....being maintained and calibrated at great expense while gathering dust and not being used.  Meanwhile, the search for real, workable solutions gets shortchanged because it requires boring old brain work instead of some shiny instantly gratifying toy.

Merde! 

Fred

P.s. Here's the applicable section of the Washington air regs for insignificant/exempt sources.  They're very close to CFR 40, but much easier to read.  It starts at 173-401-530 and goes through 533
http://apps.leg.wa.gov/wac/default.aspx?cite=173-401-530

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Zimmer, Catherine (PSC)
Sent: Tuesday, June 19, 2012 6:35 AM
To: Volkman, Jennifer (MPCA); pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Drug Terminator

Hi All,
There will likely be dioxins in the ash, and up the stack.  Many pharmaceuticals contain chlorine, in an organic form, which is a precursor to dioxin formation.  The burn in the Terminator will not likely be very controlled, dioxins could very readily form.  I doubt this type of incinerator would meet air quality or ash standards.  The ash may need management as hazardous waste.  

Hope this helps.

Very truly yours,

Catherine Zimmer, MS, BSMT
Industry Leader, Environmental and Regulatory
PSC Healthcare Services
Office:  651.645.7509
Mobile: 713.829.6365
www.pscnow.com
Catherine.zimmer at pscnow.com

Live green now!
Reduce, reuse, repair, recycle.



-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Volkman, Jennifer (MPCA)
Sent: Monday, June 18, 2012 4:36 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Drug Terminator

These units can't be operated in MN because they cannot meet our air quality permit requirements--or it would be cost prohibitive to meet them. We've never gotten to the ash discussion because of this. They should be able to send you ash test results if they are certain enough to actually swear about it? I'm guessing any mercury content would go out the stack and there could be a few RCRA metals in the ash, maybe barium, chromium, selenium from vitamins and various other drugs. I don't know that any other metals are used commonly in pharms.

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Terri Buckner
Sent: Monday, June 18, 2012 3:25 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Drug Terminator

Hello,

Our police department wants to purchase a portable incinerator called the Drug Terminator. The product sheet says the incinerator will reduce the drugs down to 1-2% ash. When I spoke with the sales person at one of the distributors, he swore the ash is non-toxic and can be thrown into the trash. I'm being skeptical. Does anyone else have one of these? Do you consider the ash to be non-toxic?

Thanks, Terri
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