[Pharmwaste] FW: Take back programs and "pharmas"
Gilliam, Allen
GILLIAM@adeq.state.ar.us
Fri, 14 Jan 2005 09:35:04 -0600
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thanks for the lode of info Alice,
=20
if you don't mind, i'd like to use a modified version of your survey
questionnaire for our city folks to send out to their pharmacies and
nursing home facilities. i'll have to make the distinction to the
cities regarding reverse distributors and the returns industries. if
the returns industry just "dispose" of them into the sewer system or
incinerate (with wet air scrubbers?), we're still in the dilemma on how
to advise/require them to dispose of them differently. or via your
phone survey (if you talked to any returns industries?), did you get any
hint these folks were taking their stuff to landfills? =20
=20
emerging pollutants of concern (seems to be mostly pharmas) coming out
of our wastewater treatment plants "untreated or destroyed" is something
rather new on the national pretreatment scene to my knowledge.
identifying what's passing through is the first hurdle since testing for
these exotic compounds hasn't been required in most areas of the U.S.=20
=20
if and when any cities are identified in violation of biomonitoring or
w.e.t. limits (we don't even know yet what's aquatically toxic as
opposed to just "observed effects" [growth, reproductivity, etc] do we?)
then what will the local wastewater treatment officials have to do to
mitigate the incoming exotics?
=20
glynda? are you absorbing some my concerns that might fit (or already
fit?) into your presentation in irving? the tx tceq pretreatment
coordinator that attended your seminar a few days ago said you did a
fantastic job!
=20
gotta git and thanx again for the links,
=20
allen gilliam
adeq state pretreatment coordinator
501.682.0625
-----Original Message-----
From: Chapman, Alice [mailto:Alice.Chapman@METROKC.GOV]=20
Sent: Thursday, January 13, 2005 11:32 PM
To: Gilliam, Allen; pharmwaste@lists.dep.state.fl.us
Cc: glyndata@io.com; Ann Heil
Subject: RE: [Pharmwaste] FW: Take back programs and "pharmas"
=09
=09
Hello Allen,=20
Take Back Programs:=20
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=20
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=20
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. =20
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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<DIV>
<DIV><SPAN class=3D203004414-14012005><FONT face=3DArial color=3D#0000ff =
size=3D2>thanks=20
for the lode of info Alice,</FONT></SPAN></DIV>
<DIV><SPAN class=3D203004414-14012005><FONT face=3DArial color=3D#0000ff =
size=3D2></FONT></SPAN> </DIV>
<DIV><SPAN class=3D203004414-14012005><FONT face=3DArial color=3D#0000ff =
size=3D2>if you=20
don't mind, i'd like to use a modified version of your survey =
questionnaire for=20
our city folks to send out to their pharmacies and nursing home=20
facilities. <SPAN class=3D390195214-14012005> i'll have to make=20
the distinction to the cities regarding reverse distributors and =
the=20
returns industries. if the returns industry just "dispose" of them =
into=20
the sewer system or incinerate (with wet air scrubbers?), we're still in =
the=20
dilemma on how to advise/require them to dispose of them=20
differently. </SPAN></FONT></SPAN><SPAN =
class=3D203004414-14012005><FONT=20
face=3DArial color=3D#0000ff size=3D2><SPAN =
class=3D390195214-14012005>or via your phone=20
survey (if you talked to any returns industries?), did you get any hint =
these=20
folks were taking their stuff to=20
landfills? </SPAN> </FONT></SPAN></DIV>
<DIV><SPAN class=3D203004414-14012005><FONT face=3DArial color=3D#0000ff =
size=3D2></FONT></SPAN> </DIV>
<DIV><SPAN class=3D203004414-14012005><FONT face=3DArial color=3D#0000ff =
size=3D2>emerging pollutants of concern (seems to be mostly pha<SPAN=20
class=3D390195214-14012005>r</SPAN>mas) coming out of our =
wastewater=20
treatment plants<SPAN class=3D390195214-14012005> "untreated or=20
destroyed"</SPAN> is something rather new on the national =
pretreatment=20
scene<SPAN class=3D390195214-14012005> to my knowledge</SPAN>. =
identifying=20
what's passing through is the first hurdle since testing for these =
exotic=20
compounds hasn't been required<SPAN class=3D390195214-14012005> in most =
areas of=20
the U.S.</SPAN> </FONT></SPAN></DIV>
<DIV><SPAN class=3D203004414-14012005><FONT face=3DArial color=3D#0000ff =
size=3D2></FONT></SPAN> </DIV>
<DIV><SPAN class=3D203004414-14012005><FONT><FONT face=3DArial><FONT=20
color=3D#0000ff><FONT size=3D2>if and when any <SPAN=20
class=3D390195214-14012005>cities </SPAN>are identified in <SPAN=20
class=3D390195214-14012005>violation of biomonitoring or w.e.t. limits=20
</SPAN>(<SPAN class=3D390195214-14012005>we don't even know =
yet what</SPAN>'s=20
aquatically toxic as opposed to just "observed effects" [growth, =
reproductivity,=20
etc]<SPAN class=3D390195214-14012005> do we?</SPAN>) then what will the =
local=20
wastewater treatment officials have to do to mitigate the incoming=20
exotics?</FONT></FONT></FONT></FONT></SPAN></DIV>
<DIV><SPAN class=3D203004414-14012005><FONT face=3DArial color=3D#0000ff =
size=3D2></FONT></SPAN> </DIV>
<DIV><SPAN class=3D203004414-14012005><SPAN =
class=3D390195214-14012005><FONT=20
face=3DArial color=3D#0000ff size=3D2>glynda? are =
you absorbing some my=20
concerns that might fit (or already fit?) into your presentation in =
irving? the tx tceq pretreatment coordinator that attended your =
seminar a=20
few days ago said you did a fantastic job!</FONT></SPAN></SPAN></DIV>
<DIV><SPAN class=3D203004414-14012005><SPAN =
class=3D390195214-14012005><FONT=20
face=3DArial color=3D#0000ff size=3D2></FONT></SPAN></SPAN> </DIV>
<DIV><SPAN class=3D203004414-14012005><SPAN =
class=3D390195214-14012005><FONT=20
face=3DArial color=3D#0000ff size=3D2>gotta git and thanx again for the=20
links,</FONT></SPAN></SPAN></DIV>
<DIV><SPAN class=3D203004414-14012005><SPAN =
class=3D390195214-14012005><FONT=20
face=3DArial color=3D#0000ff size=3D2></FONT></SPAN></SPAN> </DIV>
<DIV><SPAN class=3D203004414-14012005><SPAN =
class=3D390195214-14012005><FONT=20
face=3DArial color=3D#0000ff size=3D2>allen =
gilliam</FONT></SPAN></SPAN></DIV>
<DIV><SPAN class=3D203004414-14012005><SPAN =
class=3D390195214-14012005><FONT=20
face=3DArial color=3D#0000ff size=3D2>adeq state pretreatment=20
coordinator</FONT></SPAN></SPAN></DIV>
<DIV><SPAN class=3D203004414-14012005><SPAN =
class=3D390195214-14012005><FONT=20
face=3DArial color=3D#0000ff =
size=3D2>501.682.0625</FONT></SPAN></SPAN></DIV></DIV>
<BLOCKQUOTE dir=3Dltr style=3D"MARGIN-RIGHT: 0px">
<DIV></DIV>
<DIV class=3DOutlookMessageHeader lang=3Den-us dir=3Dltr =
align=3Dleft><FONT=20
face=3DTahoma size=3D2>-----Original Message-----<BR><B>From:</B> =
Chapman, Alice=20
[mailto:Alice.Chapman@METROKC.GOV] <BR><B>Sent:</B> Thursday, January =
13, 2005=20
11:32 PM<BR><B>To:</B> Gilliam, Allen;=20
pharmwaste@lists.dep.state.fl.us<BR><B>Cc:</B> glyndata@io.com; Ann=20
Heil<BR><B>Subject:</B> RE: [Pharmwaste] FW: Take back programs and=20
"pharmas"<BR><BR></FONT></DIV>
<P><FONT size=3D2>Hello Allen,</FONT> </P>
<P><FONT size=3D2>Take Back Programs:</FONT> <BR><FONT size=3D2>I =
completed a=20
national telephone survey of reverse distributors and compiled the =
results,=20
with a short summary of regulations that affect the industry, in a =
report=20
accessible online. You'll find it at:</FONT></P>
<P><FONT size=3D2><A=20
href=3D"http://www.govlink.org/hazwaste/publications/index.cfm#406"=20
=
target=3D_blank>http://www.govlink.org/hazwaste/publications/index.cfm#40=
6</A></FONT>=20
</P>
<P><FONT size=3D2>We used the survey data in a Resource Directory for =
our local=20
businesses with expired, unwanted or unusable pharmaceuticals. =
The=20
directory is also online at:</FONT></P>
<P><FONT size=3D2><A=20
href=3D"http://www.govlink.org/hazwaste/publications/index.cfm#407"=20
=
target=3D_blank>http://www.govlink.org/hazwaste/publications/index.cfm#40=
7</A></FONT>=20
</P>
<P><FONT size=3D2>It's easy to get confused about the difference =
between=20
"reverse distributors" (defined by DEA as able to accept controlled =
substances=20
for return to the manufacturer or disposal) and the "returns industry" =
(return=20
expired drugs to manufacturers for credit). While all returns =
industry=20
companies are reverse distributors; some reverse distributors only =
dispose of=20
drugs and don't hassle with trying to get credits back from=20
manufacturers. </FONT></P>
<P><FONT size=3D2>You asked, "What's known about the extended =
life/nursing=20
homes, home health care workers' requirements and remote/rural health=20
clinics?" These questions get at the heart of defining waste as =
either=20
household (exempt) or business (could be conditionally exempt small =
quantity=20
generators or fully regulated generators depending on the amounts per=20
site). We are sorting through these questions locally with our =
State=20
hazardous waste staff, Board of Pharmacy and others. With =
nursing homes,=20
we identified a potential regulation conflict. State nursing =
home=20
regulations say that the nursing home is responsible for disposing of =
the=20
resident's drugs, while our hazardous waste staff have typically =
viewed a=20
nursing home as a residence, and the drugs as household exempt. =
These=20
issues need further exploration before we have a clear=20
answer.</FONT></P></BLOCKQUOTE></BODY></HTML>
=00
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