[Pharmwaste] Fw: drug collection information
Charlotte A. Smith
csmith at pharmecology.com
Tue Nov 15 08:46:56 EST 2005
Hi Donna,
Of the many excellent questions you've raised, I am most concerned about
the proposed use of PharmLink for disposal. They are a reverse
distributor and according to ECHO (Enforcement and Compliance History
Online at http://www.epa.gov/echo/) PharmLink has notified EPA as a
hazardous waste generator, not as a hazardous waste treatment, storage
and disposal facility (TSDF) which they would need to be to accept and
dispose of hazardous waste. They can only generate hazardous waste when
outdated drugs are sent to them for potential credit and turn out to be
non-returnable. The collection programs I'm familiar with have used
either regional hazardous waste brokers or one of the national
companies, such as Teris, Onyx, or Clean Harbors.
While Michigan considers hazardous pharmaceutical waste to be universal
waste, as soon as it leaves the borders of the state it must be fully
manifested as hazardous waste. I do not know of any appropriate
destruction facilities in Michigan.
Charlotte A. Smith, R. Ph., M.S., HEM
President
PharmEcology Associates, LLC
200 S. Executive Drive, Suite 101
Brookfield, WI 53005
262-814-2635
Fax: 414-479-9941
csmith at pharmecology.com
www.pharmecology.com
H2E Champion for Change Award 2004
-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
Shafir.Wendi at epamail.epa.gov
Sent: Monday, November 14, 2005 12:24 PM
To: pharmwaste at lists.dep.state.fl.us
Cc: Twickler.Donna at epamail.epa.gov; Baxter.Jan at epamail.epa.gov
Subject: [Pharmwaste] Fw: drug collection information
If anyone can help, please reply to Donna Twickler at
twickler.donna at epa.gov or 312-886-6184. She has a number of questions
regarding an interesting take-back project.
Thanks
Wendi
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 at epa.gov
http://www.epa.gov/region09/waste/p2
Donna
Twickler/R5/USEP
A/US
To
11/09/2005 06:09 barbara.bickford at dnr.state.wi.us
PM cc
Phillippa Cannon/R5/USEPA/US at EPA
Subject
drug collection information
Hi Barb,
USEPA Region 5 was approached by CDC to participate in a pharmaceutical
collection program with them (and FDA) in Michigan. The focus of their
collection is antibiotics, however they will accept other solid
pharmaceuticals that are not considered controlled substances.
Apparently this is the first time CDC has done this, so they are looking
for information and support. I mentioned Wisconsin has a pharmaceutical
collection in Madison scheduled this Fall. CDC has contacts in Madison,
so they are very interested in the specifics of the Madison collection
event. I was wondering whether you could provide me with some specific
information on the collection, which I can share with CDC?
The proposed Michigan collections would involve secure drop off
containers/totes located at Meijer stores throughout Michigan, for a 3
month period. It's unclear whether these containers would be situated
in the customer area near the pharmacy or behind the counter. They will
be somehow monitored by the pharmacy staff.
The first question CDC asked is whether USEPA has any containers for
depositing the pharmaceutical bottles in the container, but would
prevent access to the drugs after they had been deposited. An example
is a mailbox type container, either attached to a wall or free standing
that is secured. USEPA Region 5 does not have this type of container
nor the ability to purchase them. Along these lines I was wondering
what type of containers Wisconsin used/will use for their one day
collection. Are you aware of containers that meet the above description
in the healthcare setting that could possibly be borrowed for the
duration of the project? I saw a medical waste contaier in the Federal
Occupational Health office today, when I received a flu shot. It was
designed like a mailbox, however it was smaller than would be needed for
pharmaceutical collections. The nurse thought there were larger
containers of the same design available for purchase.
The question I have is whether theMichigan project group had coordinated
with U.S. Drug Enforcement Agency to date. I know you have received
guidance from their DC HQ DEA office. I am not sure that the only thing
that the project team has to do is say "no controlled substances will be
collected". Do individuals always know whether their perscription is a
controlled substance? Does it matter whether or not the individual
deposits the drug directly into the container or the pharmacy staff
deposits it. How are containers typically secured? I know that the
DEA issues drive most programs to have 1 day pharm collection events,
due to the fact that a law enforcement official has to be present during
the collection.
Also, could you provide me with the name of the person at DEA you with
whom you have been coordinating? I would like to contact them
directly, to ask them if they would like to or feel they need to
participate on the work group. I would also like to ask whether they
have secure containers that could be borrowed for the 3 month duration
of the project. It is estimated that approximately 190 containers would
be needed.
CDC decided to use Phamlink (sp) for disposal. I don't know anything
about this company, but according to CDC they meet all applicable
disposal regulations (including EPAs). What company are you using for
disposal?
The last question I have is whether Wisconsin has information on the
environmental hazards associated with the improper disposal of
pharmaceuticals. We are checking with our headquarters office to
determine if there is any EPA information on this available for
distibution.
Any information you could provide would be greatly appreciated.
Thanks!
Donna
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