Summary of Capital Returns Site Visit

Site:		Capital Returns

		Milwaukee, Wisconsin

Date:		June 28, 2006	

Purpose:	To learn about the reverse distribution system as well as the
generation and management of RCRA hazardous waste at reverse
distributors.

Attendees:

U.S. EPA, Office of Solid Waste

Jessica Biegelson

Lisa Lauer

PharmEcology Associates

Charlotte Smith, President 

Capital Returns

Mary Hendrickson, Director of Quality and Regulatory Affairs

To begin the site visit, Mary Hendrickson presented a general overview
of Capital Returns and a process overview of the reverse distribution
model.  We discussed the positive and negative aspects of the possible
addition of pharmaceutical wastes to the universal waste program, as
well the drawbacks of the current RCRA system as it applies to
pharmaceutical wastes.  We then toured the facility which included the
receiving, processing and hazardous wastes storage areas.  

RCRA Challenge:

Costumer confusion – an OSHA hazardous drug does not equal a RCRA
hazardous waste

P-listed containers that are empty but are not “RCRA-empty”

Drugs that are “hazardous,” yet are not RCRA hazardous wastes

