Stewardship Plan for Covered Drugs - The Drug Takeback Solutions Foundation


SCH Number
Public Agency
California Department of Resources Recycling and Recovery
Document Title
Stewardship Plan for Covered Drugs - The Drug Takeback Solutions Foundation
Document Type
NOE - Notice of Exemption
Document Description
Senate Bill 212 (Jackson, Chapter 1001, Statutes of 2018) established the statewide Pharmaceutical and Sharps Waste Stewardship Act (Act). Stewardship programs for covered drugs are primarily required to be secure collection receptacle programs supplemented with mail-back programs. 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 covered drugs. 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 November 19, 2021, The Drug Takeback Solutions Foundation submitted to CalRecycle a stewardship plan, including an initial budget, titled Stewardship Plan for Covered Drugs, and provided an Addendum on December 16, 2021. CalRecycle approved the plan on February 16, 2022.

Contact Information

Irina Kaminer
Agency Name
California Department of Resources Recycling and Recovery
Job Title
Contact Types
Lead/Public Agency


Other Location Info
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 plan (which includes the budget) is not a "project" under CCR, Title 14 section 15378(a).

Notice of Exemption

Exempt Status
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.
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