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CHA has submitted the attached comment letter to the Environmental Protection Agency (EPA) on its proposed rule for management standards for hazardous waste pharmaceuticals. Developed in conjunction with a member workgroup, CHA’s comments are generally supportive of the proposed requirements but express concern with the overlap of state and federal law. CHA urges EPA to develop technical assistance for state agencies, ensuring that both state and federal regulations can be complied with efficiently. In addition, CHA urges EPA to delay the effective date of the final rule to no earlier than one year from its release. CHA believes that state agencies need additional time to understand the opportunities and challenges these new policies present, and develop resources to educate hospitals and health care facilities on compliance. Comments on the proposed rule are due Dec. 24.
