Meeting with EXP (September 20, 2006)

Participants:

Tanja Barrnet (consultant)

Gus Changaris (EXP)

Alex Myers (attorney for EXP)

Rob Ellis (EXP)

Mark Harvey (EXP)

Nadine Ewe (EXP)

Matt Hale (EPA)

Ross Elliott (EPA)

Jim Michael (EPA)

Trish Mercer (EPA)

Maria Vickers (EPA)

Meg McCarthy (EPA)

Purpose:  EXP has requested that EPA consider adding hazardous
pharmaceutical wastes to the universal waste program.   The purpose of
the meeting was to outline the issues surrounding the current management
practices of hazardous pharmaceutical wastes.

Notes:  EXP stated that the current system works well for reverse
distributors, but a problem arises when there are expired
pharmaceuticals that are not creditable.  EXP stated that few health
care facilities were aware of RCRA (very little time and resources for
RCRA).  EXP believed the allowing reverse distributors to apply their
expertise to all pharmaceutical wastes (including non-creditable
pharmaceuticals) would solve this problem. 

