Pharmaceutical Waste Management
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On April 22nd 2007 the Florida Department of Environmental Protection amended its hazardous waste regulations to include a new rule entitled: Universal Pharmaceutical Waste (62-730.186 F.A.C). The amendments are intended to allow flexibility in the management of hazardous waste pharmaceuticals by regulating such waste as universal waste in Florida, and to clarify standards applicable to handlers of hazardous waste pharmaceuticals. The new rule does not require generators to manage hazardous waste pharmaceuticals as universal waste. The new rule does not impose any new regulatory requirements. It merely allows a less stringent management option for persons who generate hazardous waste pharmaceuticals
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So what does this mean?
Generators of pharmaceutical waste now have a choice. They can either choose to manage hazardous waste pharmaceuticals under the Resource Conservation and Recovery Act (RCRA) or Florida's Universal Pharmaceutical Waste (UPW) rule.
RCRA regulations are more stringent and were intended to address industrial waste and bulk quantities, not healthcare setting pharmaceuticals in finished dosage forms. However, RCRA is the only Federal regulation under which waste pharmaceuticals can be treated. The absence of any RCRA treatment facilities in the state of Florida means that generators have to ship less than bulk quantities of waste out of state for treatment. Additionally, being a RCRA waste generator is subject to stringent planning, training and reporting requirements. The increased costs associated with this are obvious.
While managing pharmaceutical waste in Florida, generators can take advantage of the UPW rule by managing it under Universal Waste regulations. These are the standards the EPA set forth for fluorescent light bulbs, mercury containing devices, batteries and pesticides and were adopted by the Florida Department of Environmental Protection (FDEP). The reason why EPA developed these standards, are the very same reasons outlined above: to manage these waste streams under RCRA was too cumbersome and expensive and as a result were not being managed at all. EPA successfully streamlined the regulations to allow incentives to comply, and it worked!
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Florida is the second state in the nation to develop a rule for the management of waste pharmaceuticals as Universal Waste. The first was Michigan. The EPA is now looking to draft a similar rule, though it will be several years before they come up with anything final.
The bottom line: generators can still manage waste batteries, light bulbs, mercury devices and waste pharmaceuticals under RCRA regulations. The fact that they can be managed as Universal doesn't make them any less hazardous to the environment and human health. The fact is that the Universal Waste rules make it impractical to manage them any other way.
For information on managing waste pharmaceuticals under the UPW rule, please visit our Universal Pharmaceutical Page on this website.
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