Full Document:
RCRA Online Number: 14917
Title: EPA Response to Vorys Regarding Applicability of 40 CFR Part 266 Subpart P to Intermediate Care Facilities
Document Date: 2019-10-16
To: Amicon
From: Salyer
Organization of Recipient: Vorys, Sater, Seymour and Pease LLP
Description: Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF, also known as an ICF/ID) do not meet the definition of a long-term care facility, a type of healthcare facility in 40 CFR part 266 subpart P. 40 CFR part 266 subpart P sets standards for how healthcare facilities must manage their hazardous waste pharmaceuticals. The wastes, including pharmaceutical wastes generated by residents at ICFs, continue to be considered household wastes that are eligible for the household waste exclusion in 40 CFR 261.4(b)(1). That said, EPA strongly discourages the sewering (e.g., flushing) of pharmaceuticals. Instead, we recommend the use of pharmaceutical take-back programs to protect both human health and the environment (additional keywords: group homes, assisted living facilities, retirement communities).
Regulatory Citation(s): 266.500, 261.4
Official ORCR Policy: Yes
Associated Topic(s):
Very Small Quantity Generators (VSQG) (formerly Conditionally Exempt, CESQG),
Exclusions (RCRA),
Generators,
Hazardous Waste,
Household Hazardous Waste |
