Pharmaceutical Universal Waste Stakeholders Group
Information and Meeting Schedule
In 2013, the Department of Energy and Environmental Protection (DEEP) established a Pharmaceutical Universal Waste Stakeholders Group, comprised of professionals with broad pharmaceutical expertise, to assist in the development of the regulations to allow hazardous pharmaceutical wastes to be managed as a Universal Waste in Connecticut. The group met several times in 2013 and 2014 and DEEP had intended to begin drafting an amendment to Connecticut's Hazardous Waste Management Regulations providing for the regulation of discarded pharmaceuticals as Universal Waste. However, In a Proposed Rule dated September 25, 2015, EPA indicated that it intended to create a uniform, nationwide system for the management of discarded pharmaceuticals, and prohibited states from listing such pharmaceuticals as Universal Waste. As a result, the efforts of the Pharmaceutical Universal Waste Stakeholders Group were discontinued. However, the information pertaining to this stakeholder process is, for now, being preserved on this web page since it documents this significant stakeholder process, and because many of the resources and links provided below continue to be useful to those that are interested in the management of pharmaceutical waste in Connecticut.
Background
On December 2, 2008, EPA public noticed a proposal to add hazardous pharmaceutical waste to the Universal Waste Rule (UWR) that was originally promulgated on May 11, 1995. The UWR modified the Resource Conservation and Recovery Act’s (RCRA) hazardous waste regulations (40 CFR Parts 260 through 265) by providing streamlined requirements for the collection, management and disposal of a group of hazardous wastes that are widely produced by many different types of businesses. EPA’s 2008 proposed rule was meant to facilitate the appropriate management and disposal of hazardous pharmaceutical wastes. Due to extensive and conflicting comments , and concern over the lack of notification and tracking requirements, EPA decided to not finalize the 2008 proposal. Instead, developed a new proposal for the sector-based management of hazardous waste pharmaceuticals which may not be as flexible as a universal waste designation.
Before 2008, DEEP has been actively working on the issues surrounding the proper management and disposal of hazardous waste pharmaceuticals. The Department provided comments to EPA in favor of their December 2008 proposal to add hazardous waste pharmaceuticals to the UWR. The Department is now advocating for change through a State-initiated universal waste listing. However, until promulgation of the proposed regulations, generators of hazardous pharmaceutical waste must manage such waste in accordance with Connecticut’s Hazardous Waste Management Regulations.
The Department will be performing the core drafting of the proposed regulations during the winter of 2013 to 2014. The draft proposed regulations will be examined by staff from the Department, the Legislative Commissioner’s Office and the Office of the Attorney General in the spring of 2014. The Department plans to revise the draft proposed regulations, as appropriate, during the summer of 2014, and public notice the draft proposed regulations in the fall of 2014.
Meeting Information
The Pharmaceutical Stakeholders Group held several meetings in 2013 and 2014. Agendas and other information associated with these meetings are provided below. For more information regarding these meetings or the information provided below, please contact Michele DiNoia by phone at 860-424-3816 or email her at michele.dinoia@ct.gov.
Agendas and Other Materials |
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11/12/14 | Agenda |
10/08/14 | Agenda |
Agenda
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6/11/14 |
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5/14/14 | Agenda |
4/9/14 | |
3/12/14 | Agenda |
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Agendas and Other Materials |
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12/11/13 | |
Additional Resources
Connecticut and Other States Universal Waste Regulations and Policies
- Connecticut Universal Waste Webpage
- Florida Pharmaceutical Universal Waste Regulations
- Michigan Pharmaceutical Universal Waste Regulations
(see specifically R 299.9228) - Minnesota Pollution Control Agency Pharmaceutical Waste Information
- Washington State Department of Ecology Pharmaceutical Waste Information
- Wisconsin Department of Natural Resources Pharmaceutical Waste Information
Drug Enforcement Administration
- DOJ/DEA Final Rule Concerning the Disposal of Controlled Substances - September 9, 2014
- DOJ/DEA Notice of Proposed Rulemaking Concerning the Disposal of Controlled Substances - December 21, 2012
State and Federal Interpretive Letters
- DEP Letter to the Army Concerning Waste Pharmaceuticals (September 14, 1998)
- EPA Letter Concerning Containers that Once Held P-listed Pharmaceuticals (November 4, 2011)
NIOSH and OSHA
- Federal Register Notice Concerning the 2012 Update of the NIOSH List
- NIOSH List of Antineoplastic and Other Hazardous Drugs (September 2014)
- OSHA Technical Manual, Section VI: Chapter 2
Guidance Documents
- Managing Pharmaceutical Waste: a 10-Step Blueprint for Healthcare Facilities (August 2008)
- EPA Guidance Document: BMPs for Unused Pharmaceuticals at Health Care Facilities (Draft August 26, 2010)
- Collecting Unwanted Medications: The Legal and Safe Way (NERC, January 2009)
- Holding an Unwanted Medication Collection as Part of a Household Hazardous Waste Event (NERC, September 2006)
- Managing Empty Medication Containers (NERC, November 2005)
Association Websites
- Connecticut Hospital Association
- Connecticut Pharmacists Association
- Connecticut Veterinary Medical Association
- Healthcare Distribution Management Association
- Northeast Waste Management Officials’ Association (NEWMOA)
- Product Stewardship Institute (PSI)
Other Relevant Documents/Information
- Proposal to State-list Hazardous Waste Pharmaceuticals as a Universal Waste - A PowerPoint Presentation Given by Michele DiNoia at the September 26, 2014 Conference for Sharing Sustainable Solutions for Healthcare Facilities hosted by Yale-New Haven Hospital
- CT DEEP Comments on the 2/14/2014 EPA Notice of Data Availability for Hazardous Waste Management in the Retail Sector
- Docket Webpage for the 2/14/2014 EPA Notice of Data Availability for Hazardous Waste Management in the Retail Sector
- Federal "Drug Quality and Security Act" and "Drug Supply Chain Security Act" - November 13, 2013
- List of Pharmaceuticals that are Potential Hazardous Wastes (Florida DEP)
- Managing Pharmaceutical Waste - A PowerPoint Presentation Given by Charlotte Smith of PharmEcology During the CT Hospital Environmental Roundtable Meeting, September 8, 2005
- Yale University Response to EPA December 2008 Proposal
Content Last Updated February 4, 2020