                   EPA/HQ Summary  -  Meeting with HDA et al

Attendees

HDA:		 	Anita Ducca

Inmar/Med-Turn:	Erica Burwell

Inmar's outside counsel: Noelle Wooten

RegNet:		Bob Fensterheim

EPA/HQ: 	Betsy Devlin, Kristin Fitzgerald, Richard Huggins, Barnes Johnson, Christina Langlois-Miller, Laura Stanley, Jessica Young

Date:			February 13, 2018

Location:  		EPA/HQ 

Summary

EPA HQ met with representatives and members of the Healthcare Distribution Alliance (HDA) to discuss the Hazardous Waste Pharmaceuticals Proposed Rule.  HDA discussed how wholesale distributors expect to be regulated under the Drug Supply Chain and Security Act. Inmar mentioned that if they can't read the National Drug Code (NDC) on the container, or if the container is broken, leaking or damaged, then no credit is given. They reiterated that they believe that the 1981 Merck letter (RCRA Online #11012) is the "correct interpretation" about when pharmaceuticals going through reverse distribution should be considered waste.

Also see PP slides that HDA presented.


