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EPA Proposes Pharmaceutical Waste Disposal Study

On August 12, 2008, the US Environmental Protection Agency (EPA) published a notice in the Federal Register announcing their intention to submit a detailed questionnaire to hospitals, long-term care facilities, hospices, and veterinary hospitals regarding pharmaceutical waste disposal methods.  According to the EPA, the intent of the questionnaire is to obtain a national picture of unused pharmaceuticals management and disposal practices including 1) factors driving current disposal practices 2) information on the amount and identities of unused pharmaceuticals currently disposed of via the drain or flushing and 3) alternatives to drain disposal and flushing.

The EPA estimates that there are 21,446 medical facilities and 2,830 veterinary facilities in the targeted study group and have proposed mailing 3,544 questionnaires to obtain a statistical sample of the group.  Participation will be mandatory for those receiving the questionnaire and the EPA has included penalties for non-compliance with the information collection request.  Those receiving the questionnaire will have 60 days to complete and return the packet.

The questionnaire in its current form asks for facility data including one year of financial data (2007), one year of general data on pharmaceutical waste disposal methods and costs, and one month of detailed tracking data of pharmaceutical waste disposal methods.  Additionally, the EPA is seeking information on alternative methods for the management of unused pharmaceuticals and the costs associated with these methods.

The EPA intends to utilize the information gained from this survey to identify the best management practices that are currently available and affordable in an effort to reduce the amount of pharmaceutical waste that is entering the waterways of the United States due to current disposal methods.  In 2006, the EPA released the Final Effluent Guidelines Plan which identified Healthcare as one of the target industries requiring further study.  Information gathered from this survey will also be used to better determine the need for categorical effluent guidelines for the healthcare and veterinary industries.

The complete text of the proposed questionnaire and links to supporting data can be viewed at http://www.epa.gov/guide/304m/.

The EPA is seeking comment on the proposed survey.  The public comment period ends November 12, 2008. You can submit your comments, data and information for the Study of Unused Pharmaceuticals from Medical and Veterinary Facilities, Docket ID No. EPA-HQ-OW-2008-0517, by one of the following methods: 1) http://www.regulations.gov. Follow the on-line instructions for submitting comments. 2) E-mail: OW-Docket@epa.gov, Attention Docket ID No. EPA-HQ-OW-2008-0517. You can also submit comments by mail and hand delivery.  See the Federal Register notice for additional instructions on submitting comments.

Questions regarding the EPA’s proposed pharmaceutical waste disposal study can be directed to Wayne Bates at Capaccio Environmental Engineering, Inc. at (508) 970-0033 x121 or by e-mail at wbates@capaccio.com.

 

 

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