Summary of Guaranteed Returns Site Visit

Site:		Guaranteed Returns

		Holbrook, NY

Date:		March 28, 2006

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

Attendees:

U.S. EPA, Office of Solid Waste

Meg McCarthy

Lisa Lauer

Guaranteed Returns

Jerry Meekins – Compliance Manager

Site visit began with a tour of the facility which included the
Receiving, Processing, Shipping and Hazardous Waste Storage areas. 
During the tour, Mr. Meekins provided an overview of each area as well
as addressed questions.  After the tour, Mr. Meekins presented an
overview of the reverse distributor industry and Guaranteed Returns. 
Specifically, we discussed the types of pharmaceuticals that are
received, how a waste determination is made and how wastes are managed. 
 

Guaranteed Returns’ RCRA Challenges:

P-listed wastes – the low accumulation threshold

90-day accumulation for large quantity generators – not accumulating
enough hazardous waste in a 90-day period to make shipment via a
hazardous waste transporter cost-effective.

  

