## RE: Hazardous waste pharmaceuticals management Kelsey, John C [kelseyj@cleanharbors.com] Sent: Tuesday, September 10, 2013 6:55 PM To: David Metz

David Across all methods, but incineration is the primary by far for Pharmaceuticals, close to 100%. The weight per 55 varies not only by industry but also customer. Solid is generally 140 - 275 pounds, liquid 250 - 400, regardless of industry. John -----Original Message----- From: David Metz [ mailto:DMetz@indecon.com ] Sent: Tuesday, September 10, 2013 2:57 PM To: Kelsey, John C Subject: RE: Hazardous waste pharmaceuticals management Hi John, Just a couple of follow-up questions: 1) Does the 5-15% price premium for stand-alone (not affiliated with a parent) SQGs apply to all management methods, or just specifically incineration? 2) Broadly-speaking, across all industries (not just healthcare) do you have a sense of the weight of a filled 55-gallon drum when it is transported off-site? I assume this varies considerably by industry and type of waste, so if it is easier to estimate this for solid waste versus liquid waste that would be helpful. (a range would also be useful) Thanks again, David

-----Original Message----- From: Kelsey, John C [ mailto:kelseyj@cleanharbors.com ] Sent: Thursday, August 29, 2013 12:48 PM To: David Metz Subject: RE: Hazardous waste pharmaceuticals management David Please see answers below. As always, let me know if there are more questions. John

-----Original Message----- From: David Metz [ mailto:DMetz@indecon.com ] Sent: Tuesday, August 27, 2013 11:12 AM To: Kelsey, John C Subject: RE: Hazardous waste pharmaceuticals management Hi John, RE: Hazardous waste pharmaceuticals management https://exmail.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

1 of 8 6/18/2015 7:04 PMI hope you are doing well. I have two follow-up questions, as we are working to draft an economic assessment of EPA's hazardous waste generator requirements. 1) Are you aware if large quantity generators who manage their hazardous waste through incineration receive bulk quantity "discounts" relative to very small quantity generators (on a per ton or per drum basis)? Can you estimate what the incineration cost premium might be for very small quantity generators, on a percentage basis, relative to large generators? We provide pricing to our customers through our GPO contracts that have little to no discount based on SQ vs. LQ. Many of the SQ customers are owned by the same parent who owns the LQ, they get the same price. When there is a standalone SQ who is not aggregated with a parent, our pricing is a 5-15% premium. There are some contracts that are a group of SQ together and they all get the same price as if they were all LQ. 2) In terms of labeling containers, we are aware that some large generators use computerized labeling systems (their own or those of an environmental services firm). Our sense is that these labels, at a minimum, have very basic information, such as the words "hazardous waste." Do you have any sense of the additional programming (or other) costs of enhancing these labels to include additional information, including: (a) the hazards of a container’s contents (e.g., ignitable, toxic, reactive), and (b) other words identifying the contents (e.g., paint solvent waste)? Is this information already included in the "profile information" you described below? We provide these labels free of charge to our customers and they do include the contents, a description of the waste (pharmaceutical waste, solvent waste, etc.) as well as the words Hazardous Waste. The customer will put the date that they placed waste into the container first, starting the respective clock on when waste started being generated in that drum (in a Satellite or Main accumulation area). To the customer, there is no charge nor requirements for them to do this, we do it as a provider and it is generally the standard in the industry. Based on DOT description, we also provide the DOT label that corresponds with the shipping name (Class 3 for Flammable, Class 6.1 for Toxic, etc.).

Thanks again for all your help. Regards, David

David Metz Associate Industrial Economics, Incorporated (IEc) 2067 Massachusetts Ave. Cambridge, MA 02140

617.354.0074 www.indecon.com

-----Original Message----- From: Kelsey, John C [ mailto:kelseyj@cleanharbors.com ] Sent: Friday, June 28, 2013 10:22 AM To: David Metz; RETALLICK, PHILLIP G RE: Hazardous waste pharmaceuticals management https://exmail.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

2 of 8 6/18/2015 7:04 PMCc: Jason Price; Kristen Taft Subject: RE: Hazardous waste pharmaceuticals management David Details below on your questions. One item, is there any interest in seeing a program and how they work? My first real day doing this was the day I had the pleasure to visit 4 hospitals over 2 days, seeing what is different yet the same and talking through it with the customers. It may require travel but would be worth it. John -----Original Message----- From: David Metz [ mailto:DMetz@indecon.com ] Sent: Wednesday, June 26, 2013 3:54 PM To: RETALLICK, PHILLIP G Cc: Kelsey, John C; Jason Price; Kristen Taft Subject: RE: Hazardous waste pharmaceuticals management Hi Phil and John, I hope you are well. I wanted to thank you for your input on hazardous waste determinations when we spoke last in March. We currently have a few questions regarding satellite accumulation areas where we thought you may have some insights. Specifically, we are trying to understand: 1) What is the average (or most common) container size being used by generators in satellite accumulation areas? (Alternatively, could you estimate the percentage of generators you work with using, say, 55-gallon drums? Other common sizes?) The vast majority (90%+) of acute care facilities use 17-19 gallon container sizes to manage their Pharmaceutical Waste in SAAs. Some of these generators may use 2-3 containers or simply one. There are two scenarios where they use more than one container. All generators should have a separate container for Arsenic Trioxide, if they generate it as a waste, as it cannot be incinerated due to inorganic metal and lack of organic content. Not all suppliers manage it this way and not all generators understand this point. In scenario 1, the generator uses more than one container as their supplier has them sorting RCRA from Non RCRA and often due to the supplier shipment protocols. In scenario 2, the generator uses a second container to sort P listed separate from the combined U/D/Non Haz and DOT compliant items (outside Inhalers and Silver Nitrate). They gather the P listed separately so they can remain a Small Quantity Generator. 2) What information appears on container labels in satellite accumulation areas? (We understand from EPA the label should include the words “hazardous waste” and the start date of accumulation. Would generators have to take additional steps to identify (a) the contents and (b) the hazardous waste characteristics (i.e., ignitable, corrosive, reactive, toxic) of containers or do some generators already do this? Could this information easily be added to the existing container labels?) Customers are required to have the communication of what is in the container and the start date. So it includes the word hazardous waste and then the "profile" information of what is in that container. By profile information, it will include what different pharmaceutical items are placed into the container. As to the characteristics, those characteristics are on the label based on the profile itself RE: Hazardous waste pharmaceuticals management https://exmail.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

3 of 8 6/18/2015 7:04 PMfor our customers, I cannot speak for other generators. There is also communication on the container about what goes into it and what is not allowed. For instance, most hospitals and suppliers want to ensure Sharps are not placed into these containers. Others do not want P listed in the container. There are flow charts, labels and guides that are generally placed either right on the containers or at eye level where the containers are placed. Again, we greatly appreciate any input you could provide to help us understand how generators manage their satellite accumulation areas. We're available to schedule a quick call this week or next to discuss, or these may have short answers that are easy to respond to by email. Again, we greatly appreciate any input you could provide to help us understand how generators manage their satellite accumulation areas. We're available to schedule a quick call this week or next to discuss, or these may have short answers that are easy to respond to by email.

Best Regards, David

David Metz Associate Industrial Economics, Incorporated (IEc) 2067 Massachusetts Ave. Cambridge, MA 02140

617.354.0074 www.indecon.com

-----Original Message----- From: RETALLICK, PHILLIP G [ mailto:retallick.phillip@cleanharbors.com ] Sent: Monday, March 25, 2013 4:00 PM To: David Metz Cc: Kelsey, John C; Jason Price Subject: Re: Hazardous waste pharmaceuticals management Thank you and talk to you tomorrow at 10am. Phillip G. Retallick Senior Vice President, Regulatory Affairs Clean Harbors Environmental Services, Inc 400 Arbor Lake Drive, Suite B-900 Columbia, SC 29223 Office Phone: 803 691 3427 Cell Phone: 803 600 5305 retallick.phillip@cleanharbors.com Safety-First ! On Mar 25, 2013, at 2:36 PM, "David Metz" <DMetz@indecon.com> wrote: > Thanks again. Here is the call in information for Tuesday at 10AM (Eastern). > > Tel. Number: 617-299-3688 > Conference ID: 4158 > Passcode: 2468 > RE: Hazardous waste pharmaceuticals management https://exmail.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

4 of 8 6/18/2015 7:04 PM> > We look forward to speaking with you, > David > > > David Metz > Associate > Industrial Economics, Incorporated (IEc) > 2067 Massachusetts Ave. > Cambridge, MA 02140 > > 617.354.0074 > www.indecon.com > > > -----Original Message----- > From: Kelsey, John C [ mailto:kelseyj@cleanharbors.com ] > Sent: Monday, March 25, 2013 3:11 PM > To: RETALLICK, PHILLIP G; David Metz > Cc: Jason Price > Subject: RE: Hazardous waste pharmaceuticals management > > 10 am tomorrow works for me. Conference call would be terrific. > > -----Original Message----- > From: RETALLICK, PHILLIP G > Sent: Monday, March 25, 2013 3:09 PM > To: David Metz > Cc: Kelsey, John C; Jason Price > Subject: Re: Hazardous waste pharmaceuticals management > > It's good for me, David. John, are you ok with tomorrow at 10 am EDST/ 9 am CDST? > > Phillip G. Retallick, > Senior Vice President > Regulatory Affairs > > On Mar 25, 2013, at 1:57 PM, "David Metz" <DMetz@indecon.com> wrote: > >> Hi Phil, >> >> Tuesday morning at 10am (EDT) works for us as well if you are both available. So can we do that instead of Friday? >> >> I'll set up a conference line, since you are calling in from different locations, I assume. I will send this number out momentarily. >> >> Thanks, >> David >> >> >> >> -----Original Message----- >> From: RETALLICK, PHILLIP G >> [ mailto:retallick.phillip@cleanharbors.com ] >> Sent: Monday, March 25, 2013 2:23 PM >> To: David Metz >> Cc: Kelsey, John C; Jason Price >> Subject: Re: Hazardous waste pharmaceuticals management >> RE: Hazardous waste pharmaceuticals management https://ex mail.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

5 of 8 6/18/2015 7:04 PM>> Hi David. John and I are available tomorrow morning at 10am Eastern 9am Central ( I am in Texas this week). Would that work for you and your team? >> >> Regards >> >> Phil >> >> Phillip G. Retallick, >> Senior Vice President >> Regulatory Affairs >> >> On Mar 18, 2013, at 4:05 PM, "David Metz" <DMetz@indecon.com<mailto:DMetz@indecon.com>> wrote: >> >> Hi John, >> >> I hope you are doing well. Since we last spoke, Industrial Economics has continued to work with EPA’s Office of Resource Conservation and Recovery on issues related to hazardous waste generator standards. As part of this effort, currently we are trying to understand both how facilities make hazardous waste determinations and the percentage of waste streams that are determined to be non-RCRA hazardous waste (i.e., negative determination). Considering Clean Harbor’s experience in assisting generators with hazardous waste management, I was wondering if we could speak with you about any information or insights you may have on waste determinations that might inform our analysis for EPA. Again, we would greatly appreciate any help you can provide. >> >> Best Regards, >> David >> >> David Metz >> Associate >> Industrial Economics, Incorporated (IEc) >> 2067 Massachusetts Ave. >> Cambridge, MA 02140 >> >> 617.354.0074 >> www.indecon.com< http://www.indecon.com > >> >> From: Kelsey, John C [ mailto:kelseyj@cleanharbors.com ] >> Sent: Sunday, December 02, 2012 3:56 PM >> To: David Metz >> Cc: Jason Price; RETALLICK, PHILLIP G >> Subject: RE: Hazardous waste pharmaceuticals management >> >> David >> >> An intelligent guess as to what is drain vs. solid waste vs. medical waste for RCRA pharmaceuticals would be all I can do. I would say <5%, 15-20% and 80-85% for those that are not managing correctly. It would be different for non RCRA. >> >> There is no reason to “lab pack’ these materials. It is likely related to providers that service the customer that are not the end disposal facilities. Lab packing pricing varies widely and can go from pricing neutral to multiples, based on the supplier and customer. >> >> John >> >> From: David Metz [ mailto:DMetz@indecon.com ] >> Sent: Thursday, November 29, 2012 4:57 PM >> To: Kelsey, John C RE: Hazardous waste pharmaceuticals management https://exmail.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

6 of 8 6/18/2015 7:04 PM>> Cc: Jason Price >> Subject: Hazardous waste pharmaceuticals management >> >> John, >> >> I hope you had a nice Thanksgiving. Thank you again for the information you provided a few months ago on hazardous waste management, sorting, and incineration. It has been very helpful in our development of the economic analysis of the management of hazardous waste pharmaceuticals for EPA. Now that we’ve made some progress in the analysis, we have a few additional questions that we were hoping you could shed some light on. >> >> >> 1. As you know, some healthcare facilities don’t manage their hazardous waste pharmaceuticals in a manner that’s consistent with RCRA. This could include throwing unused pharmaceuticals down the drain, throwing them in the trash with municipal solid waste, and managing them as medical waste. Do you have a rough sense of the distribution across these three categories? >> >> >> >> 2. Another issue that we’re addressing in our analysis is the cost of lab packing hazardous waste pharmaceuticals, but we’ve received some conflicting information on this. Based on your experience, are hazardous waste pharmaceuticals typically lab packed, rarely lab packed, or sometimes lab packed? If they are lab packed, what does this process usually entail? Also, if EPA didn’t specifically require lab packing under the rule, would incinerators want hazardous waste pharmaceuticals to be lab packed for some reason? Also, do you have a sense of what the cost of lab packing is on average per drum of hazardous pharmaceutical waste? >> >> Thanks again for your input. We greatly appreciate your help on this. >> >> Regards, >> David >> >> >> David Metz >> Associate >> Industrial Economics, Incorporated (IEc) >> 2067 Massachusetts Ave. >> Cambridge, MA 02140 >> >> 617.354.0074 >> www.indecon.com< http://www.indecon.com > >> >> >> ________________________________ >> The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact Clean Harbors Environmental Services at 781.792.5555 and delete the material from any computer. >> >> ________________________________ >> The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact Clean Harbors Environmental Services at 781.792.5555 and delete the material from any computer. RE: Hazardous waste pharmaceuticals management https://exmail.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

7 of 8 6/18/2015 7:04 PM> > The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact Clean Harbors Environmental Services at 781.792.5555 and delete the material from any computer. The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact Clean Harbors Environmental Services at 781.792.5555 and delete the material from any computer. The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact Clean Harbors Environmental Services at 781.792.5555 and delete the material from any computer. The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact Clean Harbors Environmental Services at 781.792.5555 and delete the material from any computer. The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact Clean Harbors Environmental Services at 781.792.5555 and delete the material from any computer. RE: Hazardous waste pharmaceuticals management https://exmail.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

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