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EPARulemakingEPA-HQ-RCRA-2007-0932

Amendment to the Universal Waste Rule: Addition of Pharmaceuticals

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American Veterinary Medical Association filings
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Activity

American Veterinary Medical Association filed 3 comments on this docket between Dec 9, 2008 and Dec 24, 2015. 75 other organizations filed here. The comment window closed 1562d ago.

What American Veterinary Medical Association filed (3)

Dec 24, 2015· Comment submitted by W. Ron DeHaven, Executive Vice President and CEO, American Veterinary Medical Association (AVMA)· EPA-HQ-RCRA-2007-0932-0270

Please find comments attached.

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Jan 2, 2009· Comment submitted by W. Ron DeHaven, Executive Vice President, American Veterinary Medical Association (AVMA)· EPA-HQ-RCRA-2007-0932-0043

December 31, 2008 RCRA Docket Environmental Protection Agency Mailcode: 2822T 1200 Pennsylvania Ave., N.W. Washington, D.C. 20460 Docket ID No. EPA–HQ–RCRA–2007–0932 - Amendment to the Universal Waste Rule: Addition of Pharmaceuticals Dear Sir or Madam: I am writing on behalf of the American Veterinary Medical Association (AVMA), established in 1863 and the largest veterinary medical association in the world. As a not-for-profit association established to advance the science and art of veterinary medicine, the AVMA is the recognized national voice for the veterinary profession. The association's more than 76,000 members comprise approximately 86% of U.S. veterinarians, all of whom are involved in a myriad of areas of veterinary medical practice including private, corporate, academic, industrial, governmental, military, and public health services. The Environmental Protection Agency (EPA) is proposing to include within the "universal waste" system all pharmaceuticals that are hazardous wastes. Under this proposal, entities generating hazardous pharmaceutical wastes would have two options for managing them, depending on state rules. Facilities may choose to continue managing these hazardous wastes under the full subtitle C Resource Conservation and Recovery Act (RCRA) hazardous waste regulations (40 CFR parts 260 to 268 and 270), or they may opt to manage hazardous pharmaceutical wastes as "universal wastes" (40 CFR part 273). The AVMA applauds the EPA's continued leadership in protecting our environment. We also appreciate the EPA's initiative to seek new ways in which handlers of pharmaceuticals may dispose of pharmaceutical waste in a manner that is safe for the public health, including the health of the environment. Specifically, while the veterinary profession is a minimal contributor of hazardous pharmaceutical waste due to practices such as tight inventory control and transfer of unused pharmaceuticals back to distributors, the AVMA appreciates the EPA's initiative to provide an additional option for disposal of hazardous pharmaceuticals, allowing the disposal of pharmaceutical waste under either EPA's "Universal Waste" regulations (if finalized) or under the current RCRA regulations. The AVMA welcomes the opportunity to continue communicating with the EPA on this and other important environmental issues. Should you need any additional explanation of AVMA's comments, please feel free to contact Dr. Lynne White- Shim at 800-248-2862. ext. 6784 or at lwhite@avma.org. Respectfully, W. Ron DeHaven, DVM, MBA Executive Vice President American Veterinary Medical Association

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Dec 9, 2008· Comment submitted by W. Ron DeHaven, CEO, American Veterinary Medical Association (AVMA)· EPA-HQ-RCRA-2007-0932-0038

December 4, 2008 Office of Information and Regulatory Affairs Office of Management and Budget Attn: Desk Officer for EPA 725 17th St., N.W. Washington, D.C. 20503 Docket EPA-HQ-RCRA-2007-0932/FRL-8746-2/RIN 2050-AG39 Amendment to the Universal Waste Rule: Addition of Pharmaceuticals Dear Sir or Madam: I am writing on behalf of the American Veterinary Medical Association (AVMA), established in 1863 and the largest veterinary medical association in the world. As a not-for-profit association established to advance the science and art of veterinary medicine, the AVMA is the recognized national voice for the veterinary profession. The association's more than 76,000 members comprise approximately 86% of U.S. veterinarians, all of whom are involved in a myriad of areas of veterinary medical practice including private, corporate, academic, industrial, governmental, military, and public health services. The AVMA asserts that careful and thoughtful consideration must be given to the EPA's Proposed Rule that, if approved, would add hazardous pharmaceutical wastes to the Universal Waste Rule. We commend the EPA on its continued leadership and regulatory oversight to ensure the health of our nation's environment. However, the AVMA believes that in order to fully evaluate how the Proposed Rule would affect the veterinary profession specifically, an extended comment period is required for an intensive review. The Information Collection Request (ICR) process associated with this Proposed Rule is being implemented to make certain that approval of the EPA's proposed rule will ensure the regulated entities managing hazardous pharmaceutical wastes follow requirements, and that state inspectors can verify entities' pharmaceutical waste compliance through management records. The AVMA requests that the Office of Management and Budget (OMB) extend the comment period on the ICR for an additional 60 days, especially given the current holiday season which usually entails significant travel commitments for our leadership and staff, coupled with the AVMA's intent to discuss this issue thoroughly with our leadership and members. If approved, the deadline for submitting comments to the OMB would be March 2, 2009. Thank you for your time and consideration, and we look forward to sharing our comments on this important issue. Respectfully, W. Ron DeHaven, DVM, MBA CEO American Veterinary Medical Association cc: Ms. Lisa Lauer, EPA Office of Solid Waste

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Abstract

The purpose of this docket is to provide access to the background information that was used in the development of the rulemaking to add pharmaceuticals to the Universal Waste Rule.

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Co-filers (75)

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