EPA Seeks to Provide New Option for Regulated Pharmaceutical Waste Management

By Dr. Lynne White-Shim, Assistant Director, Scientific Activities Division

In the Dec 2, 2008 Federal Register, the Environmental Protection Agency (EPA) announced its intent to amend the Universal Waste Rule. The EPA announced that its proposed rule would facilitate better management of pharmaceutical wastes by streamlining generator requirements and encouraging generators of hazardous pharmaceutical wastes to manage them under the provisions of the Universal Waste Rule.

Currently, hazardous pharmaceutical wastes from facilities remain regulated under the Resource Conservation and Recovery Act (RCRA). Under this proposal, depending on state rules, facilities may choose to continue managing hazardous pharmaceutical wastes under the RCRA regulations, or they may opt to manage hazardous pharmaceutical wastes as "universal wastes." The Universal Waste Rule modified the RCRA's hazardous waste regulations by establishing a set of streamlined requirements for the collection of certain widely dispersed hazardous wastes, called "universal wastes."

Several AVMA committees and councils evaluated the proposal and collaborated in formulating the AVMA's response to the EPA. The AVMA asserts that while the veterinary profession is a minimal contributor of hazardous pharmaceutical waste due to practices such as tight inventory control and transfer of unused pharmaceuticals back to distributors, the AVMA appreciates the EPA's initiative to provide an additional option for disposal of hazardous pharmaceuticals, allowing the disposal of pharmaceutical waste under either EPA's "Universal Waste" regulations (if finalized) or under the current RCRA regulations.

The EPA recently announced that it is extending the comment period to March 2, 2009. For full text of AVMA's responses, please visit: http://www.avma.org/advocacy/federal/regulatory/default.asp

Do you have expertise to offer for AVMA consideration? Send your feedback to the Scientific Activities Division at ScientificIssues.