[Pharmwaste] FW: Take back programs and "pharmas"
Chapman, Alice
Alice.Chapman@METROKC.GOV
Thu, 13 Jan 2005 21:32:16 -0800
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Hello Allen,
Take Back Programs:
I completed a national telephone survey of reverse distributors and compiled
the results, with a short summary of regulations that affect the industry,
in a report accessible online. You'll find it at:
http://www.govlink.org/hazwaste/publications/index.cfm#406
We used the survey data in a Resource Directory for our local businesses
with expired, unwanted or unusable pharmaceuticals. The directory is also
online at:
http://www.govlink.org/hazwaste/publications/index.cfm#407
It's easy to get confused about the difference between "reverse
distributors" (defined by DEA as able to accept controlled substances for
return to the manufacturer or disposal) and the "returns industry" (return
expired drugs to manufacturers for credit). While all returns industry
companies are reverse distributors; some reverse distributors only dispose
of drugs and don't hassle with trying to get credits back from
manufacturers.
You asked, "What's known about the extended life/nursing homes, home health
care workers' requirements and remote/rural health clinics?" These
questions get at the heart of defining waste as either household (exempt) or
business (could be conditionally exempt small quantity generators or fully
regulated generators depending on the amounts per site). We are sorting
through these questions locally with our State hazardous waste staff, Board
of Pharmacy and others. With nursing homes, we identified a potential
regulation conflict. State nursing home regulations say that the nursing
home is responsible for disposing of the resident's drugs, while our
hazardous waste staff have typically viewed a nursing home as a residence,
and the drugs as household exempt. These issues need further exploration
before we have a clear answer.
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<TITLE>RE: [Pharmwaste] FW: Take back programs and =
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<P><FONT SIZE=3D2>Hello Allen,</FONT>
</P>
<P><FONT SIZE=3D2>Take Back Programs:</FONT>
<BR><FONT SIZE=3D2>I completed a national telephone survey of reverse =
distributors and compiled the results, with a short summary of =
regulations that affect the industry, in a report accessible =
online. You'll find it at:</FONT></P>
<P><FONT SIZE=3D2><A =
HREF=3D"http://www.govlink.org/hazwaste/publications/index.cfm#406" =
TARGET=3D"_blank">http://www.govlink.org/hazwaste/publications/index.cfm=
#406</A></FONT>
</P>
<P><FONT SIZE=3D2>We used the survey data in a Resource Directory for =
our local businesses with expired, unwanted or unusable =
pharmaceuticals. The directory is also online at:</FONT></P>
<P><FONT SIZE=3D2><A =
HREF=3D"http://www.govlink.org/hazwaste/publications/index.cfm#407" =
TARGET=3D"_blank">http://www.govlink.org/hazwaste/publications/index.cfm=
#407</A></FONT>
</P>
<P><FONT SIZE=3D2>It's easy to get confused about the difference =
between "reverse distributors" (defined by DEA as able to =
accept controlled substances for return to the manufacturer or =
disposal) and the "returns industry" (return expired drugs to =
manufacturers for credit). While all returns industry companies =
are reverse distributors; some reverse distributors only dispose of =
drugs and don't hassle with trying to get credits back from =
manufacturers. </FONT></P>
<P><FONT SIZE=3D2>You asked, "What's known about the extended =
life/nursing homes, home health care workers' requirements and =
remote/rural health clinics?" These questions get at the =
heart of defining waste as either household (exempt) or business (could =
be conditionally exempt small quantity generators or fully regulated =
generators depending on the amounts per site). We are sorting =
through these questions locally with our State hazardous waste staff, =
Board of Pharmacy and others. With nursing homes, we identified a =
potential regulation conflict. State nursing home regulations say =
that the nursing home is responsible for disposing of the resident's =
drugs, while our hazardous waste staff have typically viewed a nursing =
home as a residence, and the drugs as household exempt. These =
issues need further exploration before we have a clear =
answer.</FONT></P>
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