The Retail Industry Leaders Association (“RILA”), the Food Marketing Institute (“FMI”), the National Association of Chain Drug Stores (“NACDS”), the National Retail Federation (“NRF”), the National Grocers Association (“NGA”), and their members (collectively the “Retail Associations”) hereby submit supplemental comments in response to EPA’s proposed rule, entitled “Management Standards for Hazardous Waste Pharmaceuticals,” 80 Fed. Reg. 58,014 (September 25, 2015) (“Pharmaceutical Proposal”). These comments build upon the comments previously submitted by the Retail Associations on December 22, 2015, and provide further input to help ensure that any final rule provides an appropriate regulatory framework for retailers of prescription pharmaceuticals, over-the-counter (“OTC”) pharmaceuticals, and dietary supplements.

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