From: Bruce Van Scoy <brucev**At_Symbol_Here**BRIGHT.NET>
Subject: Re: [DCHAS-L] Compounds washed down the drain
Date: Tue, 17 Jun 2014 20:51:46 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 007001cf8a8f$7cf633a0$76e29ae0$**At_Symbol_Here**
In-Reply-To <6E3EAA50-A750-4230-BFBB-D0A74850BE4A**At_Symbol_Here**>


Forget the sink filter/neutralization system which essentially "filters" or
collects diluted products - even if you analyzed your waste streams to
ensure that the filter "collected" the contaminant of concern you would have
to keep sampling to determining how long your collection method was good
for. Overall it is much easier (and cheaper from a disposal cost) to catch
your point source discharge, while ensuring proper disposal.

You didn't mention which state you are performing the action in. Some
states have the generic classification of "Universal Waste-Pharmaceutical"
for exactly this purpose. The generator (you) are responsible to perform a
hazardous waste characterization.

However, the vast majority of pharmaceuticals would not be either a
characteristic or listed waste and therefore regulated by RCRA.

Waste pharmaceuticals and the DI rinse-ate (or equivalent) may be allowed by
your state to be collected as a Universal Waste - Pharmaceutical. The
paperwork requirements are less than full-blown RCRA and you are eliminating
future liability from improper disposal. The final waste destruction
methods (incineration) are the same as hazardous waste.

The end result remains the same, proper and complete destruction of the
waste while not incurring future liabilities.

EPA has multiple examples of drugs found in the environment at levels high
enough to create biological impacts and I "assume" you may be
testing/working with more illegitimate drugs in your operation.

Look up the history of MPTP, it was designed as a "designer drug" which
would not be "illegal" by a lawyer with a chemistry background. But it was
discovered that it induced Parkinson's disease in 20-year old drug users.
Now, MPTP is used as a positive control to induce Parkinson's disease in
rodents to test for Parkinson's cures... and MPTP would not be classified
by RCRA as a hazardous waste.

Remember, you are still responsible to ensure proper disposal under CERCLA.

Collect the concentrate and treat it appropriately, the overall cost is a
fraction of what would result from a CERCLA action.
My thoughts only,

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of
Secretary, ACS Division of Chemical Health and Safety
Sent: Tuesday, June 17, 2014 12:09 PM
Subject: [DCHAS-L] Compounds washed down the drain

From: Sylvia Tarin Brousseau

I am a drug chemist for DOJ. We routinely use mortars, pestles, etc. in the
course of our analysis. Is there a sink filter (carbon?) to catch residual
compounds being washed down the drain? We do have a neutralization tank that
does some filtering. We have chemists that are worried about drugs (pharm
and otherwise) appearing in the food chain due to the waste water. Any
insight appreciated.

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