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Federal Register / Vol. 80, No. 186 / Friday, September 25, 2015 / Proposed Rules 58053 <br />Table 9: Active Pharmaceutical Ingredient in Residues in Single -Unit Dose Packaging <br />*Method EPA 8720B <br />**HPLC/UV <br />ND = non -detect <br />ii. Large Retailer. The second <br />stakeholder that submitted data to EPA <br />was a large retailer. Their data provide <br />the weight of active pharmaceutical <br />ingredient residues remaining in bulk <br />containers (i.e., 10D -count) of various <br />dosage strengths of warfarin. The <br />residues were quantified using HPLC— <br />W/Vis (high performance liquid <br />chromatography/ultraviolet/visible light <br />Table 10: Warfarin Residues in 100 -Gaunt Dispensing Bottles <br />detector). The data are summarized in <br />Table 10; the full results submitted to <br />EPA are included in the docket for this <br />proposed rulemaking (EPA41Qt RCRA- <br />2007-0932). <br />The results from each of the first two <br />stakeholders reflect only the weight of <br />the active pharmaceutical ingredient, <br />not the full weight of the hazardous <br />waste residues. Since it is the Agency's <br />position that it is the full weight of the <br />hazardous waste residues and not just <br />the weight of the active pharmaceutical <br />ingredients that must be counted in <br />determining generator status, we have <br />used the results to calculate the weight <br />of the total residues. In the retailer's <br />case, they have informed EPA that a <br />typical pill with a 10 mg dose of <br />Coumadin (brand name of warfarin) <br />weighs 200 mg. The active ingredient <br />represents 10 mg, or 5% of the weight <br />of the pill, while 190 mg, or 95% of the <br />weight of the pill, consists of <br />ingredients other than the active <br />ingredient. As indicated in Table 10, the <br />average weight of warfarin residue <br />remaining in a fully dispensed bottle of <br />the high dose of warfarin (10 mg) is <br />1..196 mg, if we assume that the residue <br />in the container has the same <br />proportions of ingredients (i.e., 5% of <br />tha residue is warfarin and 95% of the <br />residue are other ingredients), then <br />there would be an average of 23.92 mg <br />of total hazardous waste residue <br />remaining in a 100 -count bottle of 10 mg <br />Us of warfarin. The amount of <br />hazardous waste residue remaining in a <br />100 -count bottle of pills is very small <br />compared with the residue that would <br />remain in a 55 -gallon drum, which is <br />what the regulations for container <br />residues envisaged. <br />iii. Riverside County. The third <br />stakeholdor that provided data to EPA <br />was the Riverside County Department of <br />Environmental Health, Hazardous <br />Materials Management Branch. The <br />county received a grant from the <br />California Certified Unified Program <br />Agency (CUPA) Forum. Board to <br />conduct a study of residues remaining <br />in pharmaceutical containers. <br />Researchers at the University of <br />California, Riverside (UCR) conducted <br />the study and provided their results in <br />a report to Riverside County entitled, <br />Residue Analysis of P -Listed <br />Pharmaceutical Containers for Warfarin <br />and Nicotine. The results are <br />summarized below, but VCR's full <br />results are in the docket for this <br />Q� <br />proposed rulemaking (EPA—HRCRA- <br />2007-0932). t30 <br />The intent of the study was to <br />in <br />the third regulatory <br />approach suggested in the November <br />2011 memo discussed previously. That <br />o Sea Exhibit 2 of the CUPA Forum Board Trust <br />Fund Grant Report submitted by the Riverside <br />County pepartment of Euvvonmantal Mealth at tha <br />Co of the grant. <br />