[Pharmwaste] Do DEA regulations allow municipal waste combustor to receive mailed back controlled substances from households?

[Charlotte A. Smith]

Hi Jack,
That is definitely a question for DEA in Wash DC and your regional DEA
office. It certainly is not an accepted procedure at this time. Unless
the incinerator itself is a DEA registrant, and I don't know of any
municipal incinerators that are, the returned controlled substances need
to be received by a law enforcement officer. I suggest you write a
letter to your regional DEA and they can pass it up the chain of command
for a response. You can contact them by visiting the Diversion Office
directory at
http://www.deadiversion.usdoj.gov/drugreg/offices/index.html. Please
keep us posted as to their response!  Hope this helps. 
 
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 <http://www.pharmecology.com/> 
H2E Champion for Change Award 2004
 

  _____  

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Price,
John L.
Sent: Monday, August 14, 2006 9:51 AM
To: pharmwaste at lists.dep.state.fl.us
Cc: Tenace, Laurie; Clarke, Raoul
Subject: [Pharmwaste] Do DEA regulations allow municipal waste combustor
to receive mailed back controlled substances from households?



Our agency is submitting a grant proposal under an EPA aging initiative
for, among other things, a pilot mail back program for household
pharmaceuticals.  [You may want to submit a proposal as well, proposal
deadline in 9/29/06. See attached for details.]

 

One issue with our proposal is whether DEA regulations would permit a
municipal waste combustor to receive household unused pharmaceuticals,
including controlled substances, into a secure area of the facility.
This would be much more efficient than having the pharms returned to a
law enforcement controlled mailbox, then transshipping to the combustor
that will do the destruction, witnessed for controlled substances,
regular burn for non-controlled.  

 

 As I understand the Maine mailback pilot under development, "As long as
the postal box that accepts the returned pharmaceuticals is in
law-enforcement control, there is a specific exemption in DEA regs for
possession of controlled drugs by law-enforcement in the line of duty
(community policing for instance, or substance abuse prevention.)"
[email post to list serve 4/11/06 by Gressitt].

   

Are there exemptions or flexibilities in the DEA controlled substances
regulations that could be interpreted to allow direct return of mailed
back unused pharms from household users to the combustor that will do
the destruction? Could a secure location at the combustor be "controlled
by law enforcement" as that is defined in the controlled substances
regulations? Or is that scenario, even as a pilot program, definitely
not doable under said controlled substances regulations?

 

Any information will be appreciated.

Jack.

 

John L. (Jack) Price

Environmental Manager

Hazardous Waste Management MS 4555

Florida Department of Environmental Protection

2600 Blair Stone Road

Tallahassee, FL  32399-2400

Phone:850.245.8751

Fax: 850.245.8811

john.l.price at dep.state.fl.us

www.dep.state.fl.us/waste

Please Note:  Florida has a very broad public records law.  Most written
communications to or from state officials regarding state business are
public records available to the public and media upon request.  Your
e-mail is communications and may therefore be subject to public
disclosure.

 

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