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**Conference C all with Selin Hoboy of Stericycle**  August 6, 2012 P articipants : Selin Hoboy

– Stericycle Jason Price

– Industrial Economics (IEc) David Metz

– IEc 1. On the Reverse Distributor (RD) market:  Reverse distribution is not a major component of Stericycle’s business overall, but it is an important component of our business.  Overall, the RD market is diverse and manufacturers/distributors are major market players (other ma jor players are listed below and would recommend utilizing HDMA http://healthcaredistribution.org/ as a resource for others ) o EXP o Capital Returns

– Genco now privately held o Stericycle  Consider Reverse Logistics Association for additional information {see parenthesis above } 2. On waste companies obtaining RD licenses:  Waste companies may obtain RD licenses primarily for two reasons: 1. In order to manage DEA controlled substances. 2. In order to comply with State Board of Pharmacy requirements to handle/manage pharmaceuticals in some states.  Examples include: Veolia, Clean Harbors, Heritage 3. On hazardous pharmaceutical waste:  Approximately 8% to 15% of generated waste is hazardous waste pharmaceuticals o At the lower end of this range are ambulatory care facilities, at the higher end of the range are oncology or cancer facilities  NI OSH (CDC) provides a listing of hazardous wastes There is very little overlap between hazardous pharmaceutical waste and DEA controlled substances . Approximately 1 to 5% of pharmaceuticals are controlled substances and approximately less than 1% of controlled substances are hazardous waste On compliance with RCRA regulations:  Higher rates of compliance in States with inspections or regulations o Higher rates of compliance with P - and U - listed wastes o Lower rates of compliance with characteristic hazardous waste  Approximately 25 percent of hospitals are trying to be in compliance 25% are actively pursuing programs to ensure compliance and approximately in total 50% are considering programs to come into compliance

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 Sewering o RCRA - c om

pliant hospitals are mostly sewering only: 1. Saline and sugar -type (nutrient) solutions ; these aren’t hazardous wastes. 2. DEA controlled substances o Hospitals in compliance with RCRA do not typically sewer their hazardous waste pharmaceuticals. o CA and MN have sophisticated processes in place for hospitals to sewer controlled substance hazardous waste ; including water treatment plants granting permission for hospitals to sewer particular drug streams (with certain quantity restrictions) . o Uncertain for other States . 4. On sorting hazardous waste pharmaceuticals :  Stericycle programs requires sorting and does not currently offer “1 bucket” system .  Most customers find it more cost - effective to sort hazardous waste o Some customers switched to Stericycle from one -bucket system because the one -bucket system was too costly.  Some hospitals do find it easier for their employees however find out that 1 bucket still requires some segregation of non - compatible items for EPA and DOT reasons. 5. On management methods often employed for hazardous waste and non - RCRA pharmaceuticals :  Itis a common misconception that all medical waste is incinerated . T herefore , some believe that it is ok to put pharmaceuticals in general into these waste streams, however we continue to educate and push that this is not accurate .  Only about 12% of medical waste is incinerated.  Facilities in non - compliance with RCRA could be managing hazardous waste pharmaceuticals (1) with medical waste, (2) with sharps, (3) as MSW, or (4) through sewering. The quantity associated with each method is uncertain. (I was not sure if this was ranking in order or if you were counting the different places . I think it would be difficult to say how this breaks out in a ratio. Would recommend stating a little differently so EPA does not assume majority in RMW, Sharps MSW or sewering. There is really no clear quantity currently that we know of). 6. On training:  Training is required to educate customers to separate hazardous waste pharmaceuticals from other medical waste  Different levels of training are required for : o Environmental staff - approx. 50 - 1 5 0 for a large hospital o Nursing staff

– approx. 2 ,000 - 4,000 for a large hospital o Itis often not feasible to conduct a full 40 -hour RCRA training for all staff because of competing time demands and primary focus on patient health o Other challenges: language barrier for the environmental staff o Itwould be recommende d to have different tiered training for different staffing to provide for the simplest explanation and provide the greatest compliance.