Stewardship Plan for Home-Generated Sharps Waste - MED-Project USA
Summary
SCH Number
2021120398
Public Agency
California Department of Resources Recycling and Recovery
Document Title
Stewardship Plan for Home-Generated Sharps Waste - MED-Project USA
Document Type
NOE - Notice of Exemption
Received
Posted
12/17/2021
Document Description
Senate Bill 212 (Jackson, Chapter 1001, Statutes of 2018) established the statewide Pharmaceutical and Sharps Waste Stewardship Act (Act). Stewardship programs for home-generated sharps waste are primarily mail-back programs where ultimate users are provided sharps waste containers and mail-back materials at the point of sale. Under the Act, a program operator, which is either a covered entity or a stewardship organization established on behalf of a group of covered entities, must design and operate a statewide stewardship program for the proper collection and disposal of home-generated sharps waste. A covered entity can be a manufacturer, distributor, wholesaler, repackager, owner or licensee of a trademark or brand, or importer as defined in the Act. On September 14, 2021, MED-Project USA submitted to CalRecycle a stewardship plan, including an initial budget, titled A Product Stewardship Plan for Home-Generated Sharps Waste (Sharps Plan).
Contact Information
Name
Irina Kaminer
Agency Name
California Department of Resources Recycling and Recovery (CalRecycle)
Job Title
Attorney
Contact Types
Lead/Public Agency
Address
Phone
Location
Regions
Statewide
Other Information
The program, which implements the approved plan, is required to be implemented statewide, excepting local jurisdictions which have local stewardship program ordinances that took effect before April 18, 2018. The approval of the Sharps Plan (which includes the budget) is not a "project" under CCR, Title 14 section 15378(a).
Notice of Exemption
Exempt Status
Other
Type, Section or Code
CEQA Guidelines section 15378(a)
Reasons for Exemption
CaRecycle’s approval of stewardship plans and budgets is not a “project”. A “project” is an activity “which has a potential for resulting in either a direct physical change in the environment, or a reasonable foreseeable indirect physical change in the environment (14 CCR, section 15378(a)). CalRecycle stewardship plan and budget approvals have no direct effect on the environment and no reasonably foreseeable indirect impacts on the environment. There are no plan requirements in the proposed regulations from which any environmental impacts, direct or indirect, can be discerned. There are no standards or targets set in the proposed regulations on which to base an objective analysis of any potential impacts. To impute any general or specific environmental effects from the approval of stewardship plans and budgets would be entirely speculative, and CEQA does not require a lead agency to speculate as to potential impacts.