[Pharmwaste] Fw: drug collection information
grace.welham at deancare.com
grace.welham at deancare.com
Tue Nov 15 13:10:21 EST 2005
Hi Donna,
I'm working on the Madison, WI project, which is scheduled for Spring 2006.
If you have contacts at the CDC, I am happy to speak with them regarding
the collection.
To answer some of your questions, the containers we are using are from the
hazardous waste hauler. The meds are going directly into the drums used
for transport. I am uncertain of Michigan pharmacy law, however in
Wisconsin, the only meds that can be accepted are ones that are dispensed
in error. One of my concerns in doing a collection at the pharmacy is that
pharmacy staff would have to log each and every drug that is collected to
document the meds collected are not re-dispensed to patients. That would
cause a considerable amount of paperwork. If Michigan proceeds with the
collection at pharmacies, I strongly recommend speaking with the Michigan
Board of Pharmacy to ensure compliance with their rules and regulations.
I've copied Dianne Miller at Michigan Pharmacists Association. She will
have more information regarding Michigan pharmacy specifics.
As for the DEA, if it is possible to ensure controlled substances aren't
collected, I don't think they would care too much. However, you bring up a
good point that many patients may not be aware their medication is
controlled. DEA wants all controlled substances (Schedule II-V) to be
documented, and many patients don't realize their sleeping pill or
prescription cough syrup is controlled. If controlled substances are
collected, law enforcement must be present at the collection under USC
Section 844 and 21 CFR Section 1301.24. It would be difficult for the
pharmacist to tell a patient they can't take the medication back because a
police officer isn't present. To the patient, it's all the same thing; to
pharmacists and DEA it is not. If you want to do a continuous collection,
I would recommend asking the police department to hold the collection as
they are able to accept all medications and from there the DEA licensed haz
waste hauler can take the meds for disposal.
I have been in contact with Investigator Tom Hill at the Milwaukee DEA. If
he not able to help you, he can probably direct you to the right person.
His phone number is (414) 297-3395.
----------------------------------------------------------
Grace Welham, Pharm.D.
Drug Information Pharmacist
Dean Health System
(608) 250-1198
----------------------------------------------------------
"Charlotte A. Smith"
<csmith at pharmecology.com> To: <Shafir.Wendi at epamail.epa.gov>, <pharmwaste at lists.dep.state.fl.us>
Sent by: cc: Twickler.Donna at epamail.epa.gov, Baxter.Jan at epamail.epa.gov
pharmwaste-bounces at lists.dep. Subject: RE: [Pharmwaste] Fw: drug collection information
state.fl.us
11/15/2005 07:46 AM
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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