[Pharmwaste] RE: pharmaceutical incineration

Weinstein, Sarah (DEP) sarah.weinstein at state.ma.us
Tue Nov 13 10:09:30 EST 2012

The Massachusetts Department of Environmental Protection (MassDEP) has distributed the message below about these units to all local police departments (with help from the Mass. Association of Police Chiefs), and to all of the purchasing agents for state and local law enforcement agencies.  We also offered a MassDEP contact if any of the local agencies want more information about what they would need to do to prepare a permit application.  We are not aware of any data describing emissions from these units (although if anyone ever submits a permit application, this information would need to be provided).  We have also provided this information to the vendor of the "Drug Terminator" and "MediBurn" units.

We are aware of at least two local police departments in Massachusetts that have purchased a unit (and have not applied for the required permit), and are now talking internally about how the agency will respond.

Sarah Weinstein
Deputy Assistant Commissioner
MassDEP Bureau of Waste Prevention
Telephone:  617/574-6862
The Massachusetts Department of Environmental Protection (MassDEP) has been working to help local law enforcement agencies manage waste medications they collect from residents in accordance with the state's environmental requirements.  MassDEP has recently learned that several Massachusetts police departments may have purchased or are considering purchasing "mobile incinerators" to burn the medications they have collected as well as contraband drugs.  One unit is marketed under the trade name "Drug Terminator". Another unit is marketed under the trade name "MediBurn".

MassDEP's regulations require that the owner and operator of any incinerator must obtain MassDEP's Approval of a Comprehensive Plan Application for each Massachusetts location where the unit would be installed, before it can start operating.  This Application must be signed by a Massachusetts Registered Professional Engineer, and must include detailed engineering drawings that describe the unit's fuel, operation, and emissions.  In addition, the Application must document how the unit would meet MassDEP's requirement that it employ the "Best Available Control Technology" (BACT) for its emission control system.  Please note that this is a major MassDEP permit.  The Application fee alone (not counting engineering and other costs to prepare the Application) is $1,930. These requirements can be found in MassDEP's Air Pollution Control Regulation, 310 CMR 7.02 (see http://www.mass.gov/dep/air/laws/regulati.htm).

The U.S. Environmental Protection Agency's comparable regulation exempts units that are used by law enforcement solely to burn contraband or prohibited goods (e.g., street drugs).  However, the Massachusetts Air Pollution Control Regulation does not include this exemption.  Also, please note that EPA has recently determined that waste pharmaceuticals collected from residents cannot be classified as "contraband" or "prohibited" material, and therefore must be burned in an incinerator that meets the applicable federal incinerator emissions standards if this material is to be combusted.

MassDEP believes that the most environmentally effective way to manage waste medications collected from residents is to dispose of them at a Municipal Waste Combustor that holds all appropriate MassDEP permits.  These facilities comply with applicable state and federal incinerator emissions standards and employ sophisticated air pollution controls that protect public health from exposure to the toxic substances that may be emitted when waste medications are burned.

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Lucy, Burke
Sent: Tuesday, November 13, 2012 9:37 AM
To: Pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: pharmaceutical incineration

Re: I'd like to know if anyone is aware of any recent research on the effectiveness of portable incinerators, or if they are being used in other states.

Local Charity Purchases Drug Disposal Device
The Save Our Kids Coalition of Bowling Green has purchased a "Drug Terminator", which will provide Kentucky State Police with a way to dispose of the prescription medication they receive from a very successful program.


From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Hoffman, Deb
Sent: Friday, August 10, 2012 5:39 AM
To: Pharmwaste at lists.dep.state.fl.us<mailto:Pharmwaste at lists.dep.state.fl.us>
Cc: midwestpsc at googlegroups.com<mailto:midwestpsc at googlegroups.com>
Subject: [Pharmwaste] pharmaceutical incineration


Here in Ohio, we're discussing the usage of the portable incinerators, from an air pollution standpoint.  I've been working with a colleague in the Ohio EPA Division of Air Pollution Control.  I'd like to know if anyone is aware of any recent research on the effectiveness of portable incinerators, or if they are being used in other states.  And if you would like to share incineration options in your state, I would be interested in hearing them.

Thank you,

Deb Hoffman
Environmental Specialist
Division of Materials and Waste Management
Ohio EPA

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