[Pharmwaste] Do DEA regulations allow municipal waste combustortoreceive mailed back controlled substances from households?Wouldcombustors want to?

Johnson, Emma (ECY) EJOH461 at ECY.WA.GOV
Thu Aug 17 12:32:11 EDT 2006


Hi all-  The Washington State PH:ARM team considered using a mail back
program for collection of household pharmaceuticals initially.  Our idea
was to provide some sort of mailer to consumers and they could mail the
material directly to the Waste to Energy facility in our state.  We ran
into three logistical barriers, which I wanted to share, perhaps they do
or do not apply in your situation.

 

1.	There needs to be some authorized entity (if the mix of material
contains controlled substances, you need law enforcement) to receive the
medications.  Our incinerator could not receive the medications
directly, as they had no law enforcement capabilities there, nor were
they able to accept any sort of waste by mail.  We imagined some sort of
secure PO box located near the facility, and someone would have to take
the material from the PO box to the Waste to Energy facility.  DEA may
desire inventory control in this system, which could be quite a barrier.

2.	Volume issues.  The idea of a mailer works great for the half of
a vial that is left over, but how do you deal with the large quantity of
meds from a death in the family?
3.	Cost.  At $1.00-$5.00 per mailer (weight, volume) in postage,
that is a lot of money.  If you want 2 million people in your state to
use the program (less than half of the population in Washington) it adds
up to $2 to $10 million just in postage alone.  We weren't sure if
consumers would be willing to pay postage...  And we weren't envisioning
manufacturers paying for that cost at this early point in time.

 

Best regards

 

Emma Johnson

Washington State Department of Ecology

________________________________

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Volkman,
Jennifer
Sent: Tuesday, August 15, 2006 4:50 PM
To: Price, John L.; Charlotte A. Smith
Cc: Hickle, Garth; pharmwaste at lists.dep.state.fl.us; Schreifels, Susan;
Countryman, Linda; Tenace, Laurie; Fran Kurk
Subject: RE: [Pharmwaste] Do DEA regulations allow municipal waste
combustortoreceive mailed back controlled substances from
households?Wouldcombustors want to?

 

Hello Jack and all,

I don't know if this information will be helpful, but we are also
considering applying for a grant here, so I've been thinking about what
might work.  Ideas...some maybe not that well thought out...

 

For households located in areas where we know their waste is directed to
mixed-muni incinerators, I think we can safely educate HH's to put
old/unused pharms, including controlled substances, in their garbage
(tape up the jars, mix them with the nasties, etc first).  There is no
need to collect/mail them separately and bump into all of the regulatory
and operational issues.  Pharms generated in areas where waste goes to
landfills would be worth collecting separately and mailing in or
redirecting to a mixed-muni incinerator.  In this case, there could be
considerable transportation cost and operational barriers to get them
from the law enforcement office to the MM incinerator and it may be
simpler to render the pharms inedible/unrecognizable at the law
enforcement office and ship them with a HW contractor as a standard HW
labpack.  You'd have to comply with DOT regulations and you'd want to
work with your HW contractor to see what the options are for packaging.

 

Some of our HHW programs collect pharms, but not controlled substances.
I'll ask whether they ship the non-haz pharms in a separate lab pack or
if they just mix them in with their oil based paint.  I believe they
properly lab pack the hazardous pharms, but I know I've heard of
programs that handle the non-haz pharms in a more economical manner.  If
local law enforcement could take a bag o' pharms down to the county
public works garage and dump it in the oil paint drum, things would be
greatly simplified.  There is, however, much to know about what is haz,
non-haz and controlled.

 

Oh!  another idea.  They could be mailed in to a controlled mailbox at
the law enforcement office(s) closest to the MM incinerator, not every
one in the state.  Manufacturers could fund the system.  

 

We still need to ask DEA questions and work with them on practical, safe
options.  We still need to work with the medical community on ways to
reduce the amount of unused pharms.

 

Jnifr

	-----Original Message-----
	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: Tuesday, August 15, 2006 10:05 AM
	To: Charlotte A. Smith
	Cc: Tenace, Laurie; pharmwaste at lists.dep.state.fl.us
	Subject: RE: [Pharmwaste] Do DEA regulations allow municipal
waste combustorto receive mailed back controlled substances from
households?Would combustors want to?

	Thanks, Charlotte.  While the request worms its way through DEA,
I'm thinking we'll need a "Plan B" in case DEA says "no."  We're on a
pretty short time line.  Even if DEA says "yes," it still may be
something that a combustor could or would not want to do. These plants
are built and operated to receive municipal solid waste by the
truckload.  They may not have (or want to have) the operational
expertise or mindset to receive waste by the envelope-load, particularly
if it has to go to a secure location pretty quickly.  On the other hand,
it would be no different than their office staff receiving and
processing mail to the appropriate location, so maybe I am worrying
about a non-problem.  We'll see . . .  that's what pilots are for . . .
and now I'll end my ramblings on this topic. 

	 

	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.

	
________________________________


	From: Charlotte A. Smith [mailto:csmith at pharmecology.com] 
	Sent: Monday, August 14, 2006 10:29 PM
	To: Price, John L.; pharmwaste at lists.dep.state.fl.us
	Cc: Tenace, Laurie; Clarke, Raoul
	Subject: RE: [Pharmwaste] Do DEA regulations allow municipal
waste combustor to receive mailed back controlled substances from
households?

	 

	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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