Comments on EPA Proposed Rule: Management Standards for Hazardous Waste Pharmaceuticals

DATE: December 21, 2015

Via: EPA–HQ–RCRA–2007–0932

Our organizations represent the interests of residents in long-term care facilities and other institutional practice settings, as well as the associated professionals who are committed to caring for the frailest of our citizens. We appreciate the opportunity to comment on the Environmental Protection Agency’s (EPA) proposed rule for handling hazardous waste pharmaceuticals.

The American Society of Consultant Pharmacists (ASCP) is pleased to submit comments on behalf of the undersigned organizations on the EPA’s proposed regulation on management standards for hazardous waste pharmaceuticals.


We support efforts to ensure proper handling of hazardous waste pharmaceuticals (HWP) in the long- term care (LTC) setting. Our members are committed to take all reasonable steps to ensure the safety of the LTC residents that we serve and to protect the environment.

Our organizations do have a number of concerns with the proposed rule, such as the inclusion of assisted living facilities (ALF), continuing care retirement communities (CCRC), and nursing facilities (NF) in the definition of LTC facilities, expansion of responsibilities of the pharmacy staff, and its potential impact on the viability of small healthcare entities because of the increased compliance burden.

Click here to see the full comment letter. 

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