Consumer Healthcare Products Association filed 2 comments on this docket between Mar 6, 2009 and Jan 5, 2016. 75 other organizations filed here. The comment window closed 1562d ago.
Please find attached comments submitted on behalf of the Consumer Healthcare Products Association.
The Consumer Healthcare Products Association (CHPA), representing the leading manufacturers of nonprescription, over-the-counter medicines, believes that the EPA's implied designation of all pharmaceutical products as hazardous waste is unsound policy, since it is inaccurate and unnecessary, and does not advance the protection of environmental or human health. The unfounded implication that all unused medicines are hazardous waste undermines the scientific basis of the EPA's policymaking approach. If EPA is suggesting a change in policy, data- driven processes should be used to determine whether a specific substance is, in fact, environmentally hazardous. CHPA urges that the EPA maintain consistency with the disposal guidelines it issued in 2007, which recommended that unused medicines be disposed of in household trash. CHPA further supports broad public awareness of the environmentally sound medicine disposal recommendations of the SMARxT Disposal campaign, an initiative of the U.S. Fish & Wildlife Service, American Pharmacists Association, and the Pharmaceutical Research and Manufacturers of America (PhRMA), which follow this EPA recommendation that medicines be properly disposed of in municipal trash.
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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