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[GreenYes] Re: National Asscoiation of Counties adopts Framework EPR policy

Hi Dan,

Thanks for the followup on your concerns about or pharmaceuticals EPR program and for forwarding references on "bioremediation." of HHW. I am forwarding by copy to two representatives of our ministry of environment, as well as to two representatives of the PCPSA for their comments.

I have been away on holiday, but in my absence Paul Iverson of the Medications Return program here in BC sent a reply to a query about their program with an update to the info provided by the national PCPSA, which I quote:

"In 2007 we initially used Beisiker Enviro tech but they shut down in Feb. For the last 10 months of 2007 we used Phase Separation Solutions in Wolseley Sask. We continue to use them in 2008."

I am curious to know if a bioremediation process is widely used for the pharmaceutical discards that are recovered in HHW collection programs in the US?

All the best,


At 02:09 PM 7/28/2008, Dan Knapp wrote:
Hello Helen:

I apologize for taking so long to respond.  I had to do a little research to answer one of your questions.

I don't feel any "animus" for PPI or Bill Sheehan, only profound irritation.  In addition, I am amazed at how insulated PPI has become from reality as I see and experience it in the very nonvirtual world of reuse, recycling, and composting that I inhabit. 

It is irritating, for example, to find that PPI's  "most advanced EPR policy" located in "the Canadian province of British Columbia" has created an "EPR program" for burning BC-sourced hazardous pharmaceuticals  in an incinerator located in Alberta!  My cousins in Wisconsin may be breathing some of the dioxins and dibenzofurans this EPR "solution" is surely manufacturing!  It seems to me you should tell people in your more theoretical formulations such as your "Framework Policy" that EPR as you practice it can lead directly to incineration, which surely is a form of wasting, and therefore is contrary to PPI's assertion that "EPR + composting = Zero Waste".  (PPI Website, July 18, 2008)

This is not animus, but criticism, and I think it's legitimate criticism.  To have it dismissed as mere animus is to engage in denial as well as to refuse to engage in discussion.  

I stand corrected on where the BC pharmaceuticals are burned, but not on the burning.  Regarding your question about low-temperature disposal methods as a replacement for dangerous incineration, I believe the overall concept in our field is "bioremediation".  I decided to go look through some old Biocycle issues to see what I could find, and got three good "hits" from about a half-dozen 1990 issues.  I'm confident that there are hundreds more before and since, but here are the three I found:

1.  "Bioremediation for Hazardous Wastes", by Clarence G. Golueke and Luis K. Diaz, Biocycle, February, 1990.  General summary of bioremediation techniques and methods.

2  Abstract:  "Microbial Emulsifying Agents." by various authors; Clarence G. Golueke, Biocycle, February, 1991.  Summarizes a technical report on a small segment of the disposal process using microbes to digest carboniferous hazardous wastes. 

3.  Abstract:  "Back to Basics with Bugs." Summarizes article on bioremediation pioneer Perez, who jump-started bioremediation as a business model when it was "an exceedingly far-fetched dream," according to Dr. Golueke. "Perez not only had the foresight, he also had the "drive" and the entrepreneurial ability to (develop)... his concept into the Environmental Remediation Co.  (ERI)....  Perez differs from "many other purveyors of microbial cultures in that they provide a complete bioremediation service that begins with the provision of microorganisms and extends to the performance and completion of the entire remediation operation." 

This latter article is very interesting in view of your question.  At least one bioremediation company had already been active in the disposal marketplace when Dr. Golueke wrote about it eighteen years ago.  I'll bet there are now dozens of bioremediation companies out there.  Maybe you can do the next stage of this research and find out who they are, OK?  Be sure to share your findings with the rest of us seekers.

I conclude by quoting from your email:

 PCPSA organize transportation of large quantity of containers for destruction to government approved facilities to limit environmental impacts. All residual medications collected through the B.C. Medications Return Program was incinerated by:

1) Beiseker Envirotech Inc (formerly Cristallo Engineering Technologies Inc). Located in Beiseker, Alberta.

Due to the nature of the waste and the risk to the public, no efforts are planned to move away from incineration as the preferred method of managing the residual medications.

I would rephrase the latter sentence, "Due to the nature of the waste and the risk to the public, every effort will be made to switch to low-temperature bioremediation as a substitute for high-temperature incineration."  By the way, what is the PCPSA?

Warm regards,

Dan Knapp
Urban Ore, Inc.

On Jul 17, 2008, at 12:30 PM, Helen Spiegelman wrote:

Dear Dan,

I need to respond to your comments. I'm not sure why there is such animus between you and the Product Policy Institute, and particularly towards Bill. Both Bill and I have made every effort to understand and respond to concerns you have raised in the past about EPR and about PPI. We see you as part of the EPR solution, as we have said repeatedly.

The pharmaceutical products collected through British Columbia's EPR program do not go to the MSW incinerator in this region.

Here is the wording from the 2006 Annual Report submitted by the PharmX program to the BC government:


As per our program plan, we are limited in our ability to reduce the environmental impact of medications without affecting their legislative and regulatory obligations under Health Canada and Environment Canada. PCPSA with its Medications Return Program strives to limit environmental impacts. We urge pharmacists to recycle plastic by using recycling bins or take plastic containers used to dispatch pills and capsules for dispensing and outer containers coming from customers handing in unused or expired medications to recycling facilities when available in their communities. PCPSA organize transportation of large quantity of containers for destruction to government approved facilities to limit environmental impacts. All residual medications collected through the B.C. Medications Return Program was incinerated by:

1) Beiseker Envirotech Inc (formerly Cristallo Engineering Technologies Inc). Located in Beiseker, Alberta.

Due to the nature of the waste and the risk to the public, no efforts are planned to move away from incineration as the preferred method of managing the residual medications.

Dan, if you have information about alternative ways of treating pharmaceutical discards besides high-temperature incineration, I would really like to hear about them and recommend them to the provincial government, which approves stewardship plans under our EPR regulation.

I want to assure you that we are mobilizing against the proposed expansion of the WTE infrastructure for MSW in our region. The recent visit by Annie Leonard and Paul Connett was tremendously useful in raising public consciousness that the proposal is on the drawing board ~ we are confident that we will stop it.

You will be interested to know that the pebble that made the biggest rings in Paul Connett's recent talk here was the vision of "Resource Recovery Parks" instead of incinerators. Your model of a cluster of businesses providing recycling services is a constructive alternative to the conventional resource-destroying solutions favoured by traditionally trained municipal engineers. This idea really resonated with local elected officials, who saw it increasing their tax base rather than their municipal budgets.  Vancouver may become a site for Canada's first "Discard Mall" rather than a suite of new incinerators. We feel that the economic viability of the businesses in such a Resource Recovery Park will be enhanced by our EPR policy that prevents producers from using municipal discard disposal infrastructure.

All the best,


At 11:41 AM 7/17/2008, Dan Knapp wrote:


My concern about EPR is not EPR at all.  It's the strange mixture of 
fact and fantasy that the Product Policy Institute uses to promote it.

I attended a PPI-inspired powerpoint show given by the California 
Product Stewardship Council on EPR twice in the last month.  There I 
learned that Vancouver BC's answer to surplus, unused, discarded 
pharmaceuticals is to place them into blue plastic five-gallon 
buckets, palletize them four or five high, (a couple or three such 
pallets were shown piled high with those bright shiny containers), 
and then send them to a nearby garbage burner for incineration!  
Vancouver BC -- glowingly referred to elsewhere on PPI's website as a 
leading light in product stewardship --obligingly provides the only 
big municipal solid waste incinerator on the whole west coast for 
this treatment method that was tried and rejected just about 
everywhere to the south.  Not only that, but Vancouver BC has just 
announced plans to build six more incinerators!  This is progress 
toward zero waste?  Is PPI reviving the old garbage burner vendor 
claim that burning is recycling?

Were low-heat biological treatment methods for destroying 
pharmaceuticals ever tried in Vancouver BC?  Burning supplies heat, 
which drives chemical reactions in complex ways.  We learned from 
Barry Commoner twenty years ago that burning salt and wood creates 
dioxins where there were none before.  What does heat do to the 
complex chemicals dumped into those pretty blue containers?  Lots of 
plastics in the burner feedstock guarantees plenty of chlorine atoms 
to fashion into god knows what new compounds.

I clicked on the prompts for your new "framework policy" in the email 
announcement below and got PPI's website directory, a collection of a 
dozens of articles you folks have written about EPR.  I read the 
policy, with its libertarian undertones and overtones.  
Unfortunately, it wouldn't let me print it.  Then I clicked on an 
article that claims Canada recycles better than Washington and Oregon 
to the south, exactly and essentially because of its robust EPR 
approach.  In fact, the author claims Canada has left US recyclers 
"in the dustbin."  He doesn't mention that incineration is the 
preferred destiny for some of the products covered by EPR, at least 
in Vancouver BC.  Maybe he didn't know.

This would be silly pissing-contest stuff if it didn't mask such 
serious underlying questions.

Dan Knapp, Ph.D. and CEO
Urban Ore, Inc. , a reuse and recycling company in Berkeley, 
California since 1980
On Jul 17, 2008, at 4:53 AM, retroworks wrote:

> Bill
> My concern about EPR has always been "be careful what you wish for".
> The toxics in a product are a small snapshot of a product's
> lifecycle.  If you replace toxic lead with non-toxic tin or silver,
> you increase toxics released into the environment (tin and silver
> mining release huge amounts of mercury, and not in a lined landfill
> environment).  Moreover the net costs of extraction are different, tin
> especially tends to be mined in very sensitive regions (rain forests
> and coral reef areas), there are very few places to find it (the rare
> metals tend to be found in volcanic areas, which tend to correlate
> with rain forests).
> A careful and wise EPR policy can fine tune and improve the net
> environmental costs, but it's not to be done in a cavalier manner.
> Baby seal pelts are organic and non-toxic, a written EPR policy which
> doesn't screen out baby seal pelts will need to be rewritten, and
> risks a backlash against environmental "stewards" who have not done
> their environmental math.  I wonder if county government is the place
> for that math.  I am concerned that local government is anxious to
> adapt any revenue stream at the moment, and that a policy which
> produces revenue may not be looked at closely at all.
> Robin Ingenthron
> On Jul 15, 2:28 pm, "Bill Sheehan" <b...@no.address> wrote:
>> Kansas City, Missouri (July 15, 2008) - The National Association 
>> of Counties
>> today adopted the first national policy supporting a "framework" 
>> approach to
>> Extended Producer Responsibility (EPR). The groundbreaking national
>> resolution exemplifies growing support and momentum toward 
>> sustainable
>> production.
>> "NACo's adoption of the Extended Producer Responsibility framework 
>> is a
>> great step forward for our environment," says Commissioner Victoria
>> Reinhardt, Ramsey County, Minnesota.  "Smart design protects the 
>> environment
>> and saves money by preventing costly waste."
>> Extended Producer Responsibility is a concept whereby product 
>> manufacturers
>> are primarily responsible for the life cycle impacts of their 
>> products. The
>> "framework" concept goes beyond product-by-product approach and 
>> establishes
>> consistent principles and procedures for product makers in order 
>> to achieve
>> producer-lead responsibility for sustainable product design and 
>> management.
>> Reinhardt was the author of the framework resolution for NACo, in 
>> addition
>> to three other product-specific producer responsibility 
>> resolutions for
>> paint, electronics, and mercury-containing lamps.
>> "NACo's resolution signals the beginning of the end of local 
>> governments
>> providing "free" disposal services to producers of toxic and throw-
>> away
>> products," says Bill Sheehan, Executive Director, Product Policy 
>> Institute.
>> The Product Policy Institute works with local governments to 
>> support state
>> producer responsibility and comprehensive framework policies.
>> In January 2008, the California Integrated Waste Management Board 
>> was the
>> first state agency in the United States to adopt a framework for 
>> an Extended
>> Producer Responsibility system. With EPR implementation 
>> legislation expected
>> to be considered in California and several other states, and now 
>> with the
>> first national association of elected officials supporting the EPR
>> Framework, the effort toward achieving sustainable production gains
>> significant momentum.
>> "We are delighted that county elected officials from California 
>> and across
>> the country are united in supporting the need for product 
>> producers to
>> become part of the waste management solution," says Heidi Sanborn, 
>> Executive
>> Director, California Product Stewardship Council.
>> Both the California Product Stewardship Council (CPSC) and the 
>> Product
>> Policy Institute are dedicated to reversing the trend of 
>> manufacturers
>> producing more disposable and toxic products every year.
>> The National Association of Counties adopted the resolution in 
>> support of an
>> EPR Framework approach at their annual meeting in Kansas City, 
>> Missouri.
>> Contact:  Commissioner Victoria Reinhardt, 651-247-9958,
>> <mailto:victoria.reinha...@no.address>
>> victoria.reinha...@no.address  Bill Sheehan, Product Policy 
>> Institute,
>> 706-613-0710,  <mailto:b...@no.address>
>> b...@no.address  (
>> <> Heidi 
>> Sanborn, CPSC
>> <mailto:he...@no.address>
>> he...@no.address  (
>> <>,
>> 916-485-7753.
>> See text at  < >> index.html>
>> ###
>> *************************************
>> Bill Sheehan
>> Executive Director
>> Product Policy Institute
>> P.O. Box 48433
>> Athens, GA 30604  USA
>> Tel:  706-613-0710
>> Email:   <mailto:b...@no.address> b...@no.address
>> Web:   <>
>> *************************************
> >

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