Anonymous public comment

Document ID: EPA-HQ-RCRA-2007-0932-0041
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: December 08 2008, at 05:00 PM Eastern Standard Time
Date Posted: December 17 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: December 2 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: February 2 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 807d3168
View Document:  View as format xml

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I think clear instructions for the hospitals is necessary. I'd like to see only hazardous labeling required on storage bins in the pharmacy, and any return/waste bins. We trialed this process and some staff thought that every dose should be labeled with a sticker for Hazardous Waste/Dispose of Properly stickers and it was incredibly labor intensive and questionably valuable. If the dose is administered by the nurse, there is no waste to worry about, even residual in a syringe. Returns to the pharmacy are handled appropriately and put back into circulation and use as able. True waste could then be dispose of with any Universal Waste, appropriately labeled as such, and appropriately handled by Environmental Services of the hospital. In addition, consulting companies and reverse distributers will try to capitalize on these regulations for profit-making, and if we do not make the regulations very clear, it will continue to raise the costs of doing business in health care.

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