[Pharmwaste] Fw: [SFBAY_Pharm_Disp] Response letter from Drug Enforcement Administration

Fri, 13 May 2005 21:08:22 -0400

Kathilee Champlin did run a program in Colorado and some other states but
was eventually closed down around regulatory issues from what she has told
me.

She has moved on to other things in Colorado these days, but the letter from
DEA that has been attached here and on another email are not the only
letters that Pat's office has issued. By their very existence the central
office has demonstrated attention paid to this issue.

More than one person on this list has been in contact with DEA and even
though we may have disliked or felt that the advice or interpretations given
were harsh or unhelpful, I have personally felt that I was always dealt with
courteously, with a great deal of patience, and with clear attentiveness to
my concerns.

I do not believe that central office of DEA is not paying attention to this
issue. 

I do believe that without a formal policy as of yet, there is and will be
variation amongst the various local offices and divisions. 

I believe a policy is coming, whether or not we or I like it. Federal
legislation may be necessary to address this issue. Preparations are being
made.

The second annual "Unused Medicines Disposal Conference will be held again
in Bangor Maine in October with a date to be determined next week and will
be announced shortly thereafter.

There may be an announcement from a major medical group on this issue within
a week or so. I hope so. 

Stevan Gressitt, M.D.
207-441-0291

-----Original Message-----
From: pharmwaste-admin@lists.dep.state.fl.us
[mailto:pharmwaste-admin@lists.dep.state.fl.us] On Behalf Of
Shafir.Wendi@epamail.epa.gov
Sent: Friday, May 13, 2005 4:19 PM
To: pharmwaste@lists.dep.state.fl.us
Subject: [Pharmwaste] Fw: [SFBAY_Pharm_Disp] Response letter from Drug
Enforcement Administration

This is the response received from DEA in response to a query from
California. This was regarding take back events by various entities.
They were not encouraging.

Wendi Shafir  (WST-7)
Pollution Prevention Coordinator
US Environmental Protection Agency, Region 9
75 Hawthorne Street
San Francisco, CA 94105

415.972.3422
415.947.3530 fax

shafir.wendi@epa.gov
----- Forwarded by Wendi Shafir/R9/USEPA/US on 05/13/2005 01:15 PM -----

             "North, Karin"                                             
             <karin.north@cit                                           
             yofpaloalto.org>                                        To 
                                      "SFBAY_Pharm_Disp@yahoogroups.    
             03/24/2005 09:32         com (E-mail)"                     
             AM                       <SFBAY_Pharm_Disp@yahoogroups.com 
                                      >                                 
                                                                     cc 
                                      "Gayle Tupper (E-mail)"           
                                      <gtupper@ebmud.com>, "Ann Heil    
                                      (E-mail)" <aheil@lacsd.org>,      
                                      "Susan Hiestand (E-mail)"         
                                      <shiestand@co.sanmateo.ca.us>,    
                                      "Scott Cassel (E-mail)"           
                                      <scott@productstewardship.us>     
                                                                Subject 
                                      [SFBAY_Pharm_Disp] Response       
                                      letter from Drug Enforcement      
                                      Administration                    

Interested parties regarding pharmaceutical waste take back events:

As many of you know we have been working to clarify the rules and
regulations regarding controlled substances.  City of Palo Alto sent the
Drug Enforcement Administration (DEA) a letter that is attached asking
for clarification regarding the take-back events of pharmaceuticals,
specifically controlled substances.  Included is DEA's response letter
that explicitly states that we are not allowed to receive controlled
substances during the collection of other (non-controlled)
pharmaceuticals.

The information that we had received from our local Drug Enforcement
Administration was correct that residential waste controlled substances
is not regulated by DEA, however, possession of a controlled substance
medication by any other person other than the intended user is a
violation of federal law.  I feel that I am obligated to pass this
information onto all of you.  It looks like we will need to work with
our local law enforcement agency to ensure the proper disposal of
controlled substances.

If you have any questions regarding either of the attached letters, feel
free to contact me.

Regards,

Karin Didriksen North
Environmental Compliance Group
City of Palo Alto
650-494-7629
Fax 650-494-3531
email: karin.north@cityofpaloalto.org
www.cityofpaloalto.org/cleanbay
www.cityofpaloalto.org/waterreuse

<<PA_LettertoDEA.pdf>>  <<DEAResponseLetter.pdf>>

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