1.
Presentation by Jim Mullowney
To the EPA
January 15th
2009
Comments on Medical Waste Incinerator Regulations
Regulated medical wastes are
Blood-borne pathogens, blood,
viruses, human tissue etc.
Regulated medical waste is a blood-borne pathogen's, blood, viruses, human tissue, AIDS
virus. Regulated medical waste incinerators are very effective at destroying these
compounds; they die at about 200°F. Medical waste incinerators are very important part
of our society, and are very effective at controlling disease.
This is not regulated medical waste
They are all chemicals
What is not regulated in a medical waste, Pharmaceuticals, Drugs, and Medicine.
What do they all have in common? They are all Chemicals and some of the most
dangerous chemicals we manufacture today are Pharmaceuticals, Drugs, and Medicines.
Medical waste incinerators are not Chemical waste incinerators and are not designed to
destroy chemicals.
Does anyone know the last time the EPA regulated a Chemical as a Hazardous waste?
How about the Resource Conservation and Recovery Act in 1976. That was 32 years ago,
how many chemicals have been invented in the last 32 years, hundreds of thousands, and
it is legal to send these chemicals to a medical waste incinerator.
• Drugs
• Pharmaceuticals
• Medicine
• What do they have in
common

2.
Health facility/estimated 250,000,000 pounds of drugs a year are flushed down the drain.
This is from an article in USA Today at September 14, 2008.
“Treating the toilet as a trashcan is not a good option.” That is a quote from Ben
Grumbles EPA's top water administrator. Mr. Grumbles may be one of for your bosses.
Why do you flush drugs down the toilet? The DEA says we have to flush them. Medicare
and Medicaid both mandate that we flush the unused drugs, and the reason is to keep
them away from children, That is why we have childproof caps on medicines. If a child
gets into a medicine they tell us to call the poison control center, because it is a poison,
DRUGS ARE CHEMICALS TOO. If a person gets the medicine and takes too much of
it they may die. The reason they may die is because they took too much of the chemical.
Most people think the waste water treatment plant destroys the chemicals, they don’t. The
drugs pass thru the treatment plant and into the water system, and if you are on a septic
system the chemicals go into your leaching field and in to the drinking water system.
che·mo· ther·a·py
: the use of chemical agents in the treatment of a medical condition
Chemo-therapy. The definition of Chemotherapy is the use of a Chemical agent in the
treatment of a medical condition, which means that all medicine is Chemotherapy. I can't
watch television without finding a new disease that I didn't know I had. A commercial of
a guy that's always in the bathroom is on a boat is missing out on his life because he has
to pee too much. Personally I think he was drinking too much beer. At the end of this
commercial it says side effects may include dizziness, shortness of breath and anal
leakage. Anal leakage does not sound like a fun thing to have as a side effect. Then there
is that commercial for a drug that has a side effect that causes an erection for four hours.
Why does that commercial only come on when my daughter walks into the room?
Health facilities flush estimated 250M
pounds of drugs a year.
USA Today September 14 2008
Treating the toilet as a trash
can isn't a good option,"
says Ben Grumbles the
EPA's top water
administrator
Why do we flush
DEA, Medicare
Keep away from children

3.
This Medicine has some serious side effects.
Material Safety Data Sheet for Common
Chemotherapy Drug
This Drug May Cause:
• Cancer • Heritable Genetic Damage • Harm to the Unborn
Child • Very toxic by inhalation and if swallowed
Cytotoxic agent

4.
This is a material safety data sheet. Are all of you familiar with the Material Safety Data
sheet (MSDS)? Under a Regulation called The Right to Know, workers must be notified
of the Chemicals that they are working with and the dangers they pose if exposed. Drugs
Pharmaceuticals, and Medicines, are all Chemicals and there are material safety data
sheets for these Chemicals. This slide shows a MSDS for MUSTERGEN it’ a compound
made by Merck. I picked this out arbitrarily, not to pick on Merck.
As of any other drug this has side effects. The side effects of this drug are cancer a pretty
serious side effect. 30 % of breast cancer survivors develop a secondary cancer from the
drugs, it is well known that cytotoxic drugs cause cancer.
Hereditable genetic damage. Harm to the unborn child. It is agreed that this side
effect is worse than anal leakage. Very toxic by inhalation and if swallowed.
Cytotoxic agents does anybody know what a cytotoxic agent means. It means it is toxic
to the cell. Does anyone know how they work? The mechanism by which these cytotoxic
agents work by breaking into the blood cells attacking the DNA and breaking off the
chromosomes so when the cells splits it's a different cell hence, mutated. They attack
cancerous as well as non cancerous cells and they tend to work on fast growing cells such
as hair cells, that is why patients on some of these drugs loose their hair.
What are the fastest growing cells, how about
embryonic cells, children being born. About a
year ago a study came out that Autism is a
genetic disorder that is not hereditary, how
do you have a genetic disorder that is not
hereditary? You mutate the genes. What class
of Chemicals are designed specifically to
mutate human genes? Cytotoxic
Chemotherapy drugs. Do you think this drug is
regulated by the EPA as a waste, No it is not.
I gave a longer version of this speech on
November 20th
2008 to 100 people in New
England. We had every large hospital
represented; we had Yale New Haven,
Dartmouth Hitchcock, Mass General. Brigham
and Women's, Beth Israel, the Hartford
hospitals, the Providence hospitals, and the Worcester hospitals.
I asked the audience if they knew what cytotoxic agents were and for the most part they
said yes. I asked the audience if there were any Pharmacists the room. There were a few.
I had one in the front row. I asked the Pharmacist in the front row, have you ever made
drugs in a dose of a nano-gram per liter and he said yes of course. I asked have you ever
made a drug in a pico-gram per liter and he said sure. So I asked the audience if a nano-
gram per liter was a part per trillion. And they said yes it is a part per trillion and I asked
is a pico-gram per liter smaller than a part per trillion and they said yes.
If you take a trillion one dollar bills and stack them like a deck of cards, turn them
sideways, they would reach from Boston to the middle of Ohio.
Then I asked the pharmacist if the absorption rate of a typical cytotoxic chemotherapy
drug was 100% or was it more like 1% and his answer was more like 1%. I asked the
audience if anyone knew what absorption rate was? Then I said if you take a vitamin, two

5.
hours later you go to the bathroom and you look in the toilet your urine is bright yellow,
that is because only 5% of the vitamin you take the body absorbs in the cells.
The rest of it the passes through your body in your feces, urine, sweat glands, and
through your breath. Sometimes you take a vitamin and the smell stays on your breath for
hours. The same thing happens with cytotoxic drugs except your breath stinks for as long
as the drugs remain in the body.
Look up chemo breath on the Internet and you will find advertisements for special mints
because your breath smells terrible, as well as your whole body smells. Chemicals are
smells, what you're smelling are the chemotherapy drugs. Perfumes are chemicals.
We are all worried about second hand smoke, how about second hand Chemotherapy
drugs that dangerous at levels that you could smell them.
This is a picture of a man manufacturing a
chemotherapy drug notice he's in a
spacesuit. Do you think if you have to
make this drug in a spacesuit it can be
pretty harmful? He is wearing a spacesuit
because of OSHA regulations. I took this
picture from the June 2008 Chemical and
Engineering News the basis of the article
was that the drug companies are
subcontracting the manufacture of Active
Pharmaceutical ingredients or API’s,
because of the liability of exposure to
their employees.
He is protected by OSHA regulations from this chemical what about the rest of us, who
protects us? Do you think this Chemical is regulated by the EPA? Once the drug is made
is shipped in little vials to a pharmacy where it is compounded in different doses
sometimes with drugs.
This is how these drugs are prepared. Does
the woman in the hood look protected from
the Chemotherapy drugs. She has to be
according to OSHA. She is preparing a
nanogram per liter, how do you measure
nano-gram? Do you use a scale with the
chemical on one side and a nano-gram on
the other? No you start with a known
amount of the drug and do a series of
dilutions. What happens to the dilutions with
a much higher concentration of the drug, do they get sent to Medical waste incinerators?
I was at Brigham and Women's Hospital before Christmas and they paid $500,000 for
robot to prepare the drugs because they are too dangerous to a pharmacist to be exposed
to. They don't use the robot because the nurses are wondering if they are protected. That's
a good question.
OSHA hazardous drugs

6.
OSHA is designed to protect workers and they do. In fact they have a 30 page document
describing the dangers of cytotoxic agents and that there is zero exposure allowed. The
scary part of the document is all the research that they've done and the references to
studies that have been done over the last 20 plus years. I love the study where the
volunteers were scratched on the arm with cyclophpsphomide, a cytotoxic agent and then
checked for chromosomal aberrations in their urine, sound like a James Bond movie.
In 1985 they did a study of a nurses that were working on oncology floors they found
nurses had a spontaneous abortion rate of 4.7. That is 4.7 times the national average just
working with these chemicals. That's what prompted this document OSHA's guide to
handling hazardous drugs in 1995 that was 14 years ago.
OSHA cites carcinogenic and the mutagenic effects of these drugs they also note that
heavy concentrations of these drugs may be excreted by patients through their urine and
their feces as well as through their skin and breath. If one percent is absorbed by the body
what happens to the rest of it? Does anyone remember high school physics, the law of
conservation of mass?
• No safe exposure limit • Carcinogenic, mutagenic • OSHA recommends
the residuals be sent as regulated medical waste

7.
Drug Portal to the
World.
I took this picture from EPA
a gentleman named Christian
Daughton who is the Chief of
research and development of
the EPA. We already talked
about the guy in the left and
how to solve that problem by
not dumping drugs down the
drain but we don't want to do
is put these chemicals into
Medical Waste Incinerators
that are designed to kill germs and are not designed to destroy Chemicals. These
Medicines, Drugs, Pharmaceuticals are Chemicals and need to be sent to Chemical waste
incinerators.
The guy on the right is a bigger problem what we do about him. We really don't care how
much aspirin is in the water or Tylenol, Prozac. We do care how many cytotoxic agents
that are effective on a molecular level are released into the environment through the
excrement of the patient on chemotherapy drugs. I know it sounds crazy but we need
to collect the waste from these patients. We need to make sure this waste is not sent to a
Medical Waste Incinerator.
What should we do with the human excrement from patients on Chemotherapy?
Collect it, chemically bind it and send it to Canada. Maybe not Canada, we should
send it to a landfill in the desert that gets little rainfall and is far from a drinking water
source. We know who is on these drugs, how long they stay in the body, and how to
collect it.
OSHA has a list of these drugs; they are called Hazardous Drugs or HD’s. These Drugs
are too dangerous for human exposure; there are about 60 of them mostly cytotoxic
drugs. NIOSH has another list that is more updated with another 140 Chemicals used as
drugs and together there are about 200 medicines.
We know long a drugs stays in a human body, it is written on the prescription and is
mandated by the FDA. Sometimes it's four hours sometimes it's three days it varies by
drug but we do know that information and with only 1% of the drug that nearly kills the
patient 99% of it going down the toilet into a septic system we as a society need to care
where that 99% goes.
It is well known that Chemotherapy Drugs kill the bacteria in a septic system, these are
chemicals they are not alive. They go through the septic system and go into the water
system. If you're on a septic system you probably on a well therefore it's going directly
into your drinking water. If you're on town drinking water these cytotoxic agents are
going into the water system that feeds the town drinking water so you are giving
chemotherapy to everyone that drinks the water, takes a shower or otherwise uses the
water.

8.
The collection of human excrement with
cytotoxic drugs will happen
• Our medical waste incinerators are
not capable of destroying these
chemicals
Eventually we will be collecting the excrement
from patients on chemotherapy drugs and we
need to make sure that this excrement is not sent
to medical waste incinerators.
I personally believe that even chemical waste incinerators
are not effective on destroying these chemicals.
Medical waste incinerators do not look like this. Just
because you can't see the smoke does not mean that the chemicals are not there.
I believe the safest way to handle it is to mix with a binding agent, seal up and send
to a secure landfill in the area that has no groundwater and little rainwater. I as well
as others know that cytotoxic drugs are causing childhood diseases such as Autism, and
are the major cause of cancer in this generation.
Are there any questions?
Q. How is this problem affecting our food supply?
A. Good question, I live in the Boston area and we may have the highest concentration of
patients on chemotherapy drugs in the world, all the waste from Boston sewers goes to
the waste treatment plant on Deer Island in Boston Harbor. This plant, like a Medical
waste Incinerator is designed to destroy germs, not chemicals. Some of the drugs are
concentrated in the sludge and the rest are sent into the Atlantic Ocean. The sludge is sent
across the harbor to Quincy via barge to be dried and converted to fertilizer to be sold to
farmers all over the USA to make our food.
Yummy.
Thanks for listening to me
Sincerely
Jim Mullowney
Newport, RI
Copyright February 2009
Edited by Briana Whitt