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0 Page 2 of 2 <br /> 3. AB 1442 exempts from the definition of"pharmaceutical waste" any pharmaceutical that"is being <br /> sent"to a properly licensed"reverse distributor,"provided that if the reverse distributor is located in <br /> California, it must also be a permitted transfer station. The self-transport/common carrier provision <br /> described in the preceding paragraph would therefore appear to be moot with respect to a pharmaceutical <br /> sent to a reverse distributor in accordance with this exemption given that, based on our communications <br /> with individuals involved in drafting AB 1442,this exemption is intended to apply to pharmaceuticals <br /> throughout the reverse distribution process, including while such items are awaiting shipment at a store or <br /> distribution center, during transportation to a distribution center for interim processing, and/or during <br /> transportation to the reverse distributor. This provision appears to enable regulated entities to send all <br /> "pharmaceuticals" into reverse distribution, regardless of whether or not such items are a waste,for <br /> characterization by the reverse distributor and credit, disposal, or other non-waste disposition, as <br /> applicable. Note, however,that the exemption applies only where the pharmaceutical is being sent to a <br /> reverse distributor that satisfies the requirements set forth in AB 1442. <br /> Taking full advantage of the benefits of AB 1442 will likely require adjustments to most regulated <br /> entities' waste management programs because, among other things, AB 1442 does not apply to any <br /> prescription or over-the-counter items that would be CRA-hazardous waste if disposed. Accordingly, it <br /> will be necessary to develop, roll out, and train personnel to implement a program for distinguishing and <br /> segregating RCRA-hazardous pharmacy waste from pharmaceutical wastes not regulated by RCRA. <br /> Notwithstanding the drafters' stated intent with respect to AB 1442, the language of the bill as interpreted <br /> by enforcement authorities and the courts will ultimately determine the usefulness of AB 1442 to the <br /> regulated community. <br /> From: Trinh, Catherine N. <br /> Sent: Wednesday, August 06, 2014 2:08 PM <br /> To: Breshears, Grant <br /> Subject: Guaranteed Returns <br /> Hi Grant, <br /> Do you use Guaranteed Returns for your outdated meds? Do we have a Sutter contract with them? <br /> The San Joaquin County waste inspector is asking about our pharmaceutical waste stream and has some <br /> questions about the Guaranteed Returns policies with regards to the non-credited items that are disposed. <br /> Thanks, <br /> Cath <br /> Catherine N.Trinh, Pharml) <br /> Pharmacy Supervisor <br /> Sutter Tracy Community Hospital <br /> Office Phone:209-833-2437 <br /> Pharmacy Phone:209-832-6004 <br /> Fax:209-832-6599 <br /> *Confidentiality Notice:This email is for the sole use of the intended recipient and may contain material that is <br /> confidential and protected by state and federal regulations.If you are not the intended recipient please immediately <br /> delete it and contact the sender. <br /> 8/26/2014 <br />