[Pharmwaste] RE: DEA regulatory change: some real traction?

Tue Jan 31 09:55:20 EST 2006

I confirm Charlotte's description.

Stevan Gressitt, M.D.

On Tue, 31 Jan 2006 08:51:46 -0600
 "Charlotte A. Smith" <csmith at pharmecology.com> wrote:
> Hi John,
> 
> At the Maine conference hosted by Dr. Gressitt I
> presented a model for
> consumer take-back using reverse distributors. During the
> discussion
> period, several of us asked the DEA representative
> specifically if they
> would consider a modification in the regulations to
> enable that process
> to take place. Andy McFaul from DEA said that a well
> drafted letter from
> representatives of RDs to DEA describing the process and
> supported by
> other regulatory bodies, such as state boards of pharmacy
> and controlled
> substances boards, would be considered. He encouraged
> actual draft
> language. I believe that process has begun although I am
> not involved
> with it at this time. I suspect the willingness to
> consider such a
> proposal is being driven by the incessant questions being
> received by
> DEA as to how best to bring unused controlled substances
> back out of the
> market. 
> 
>  
> 
> 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
> 
>   _____  
> 
> From: Price, John L.
> [mailto:John.L.Price at dep.state.fl.us] 
> Sent: Tuesday, January 31, 2006 8:18 AM
> To: pharmwaste at lists.dep.state.fl.us
> Cc: Charlotte A. Smith; Lucy Doroshko; Andria Ventura;
> Scott at ProductStewardship.US
> Subject: DEA regulatory change: some real traction?
> 
>  
> 
> Charlotte: Does "a movement afoot" mean that there is
> finally some
> traction at or within DEA for a regulatory change in
> response to ongoing
> requests from collection programs? Or are you referring
> to the ongoing
> clatter from community programs continuing to request a
> regulatory
> change? From the email traffic that I've seen on this
> issue, so far it
> seems that everybody except DEA has the stomach for a
> regulatory change
> regarding take back of controlled substances.  If DEA is
> getting on
> board, that's progress.
> 
> Thanks, 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: pharmwaste-bounces at lists.dep.state.fl.us
> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On
> Behalf Of Charlotte
> A. Smith
> Sent: Monday, January 30, 2006 4:50 PM
> To: Lucy Doroshko; Andria Ventura;
> pharmwaste at lists.dep.state.fl.us
> Subject: RE: [Pharmwaste] RE: Pharmwaste Digest, Vol 3,
> Issue 12
> 
>  
> 
> Hello! There is a movement afoot to get DEA to change the
> regulations to
> enable reverse distributors to be able to accept
> controlled substances
> from consumer via the mail. This already happens to some
> extent with
> product recalls. Some of the reverse distributors, such
> as Capital
> Returns, are researching this approach. Consumers could
> receive mailback
> instructions when they pick up their prescriptions at the
> pharmacy. Once
> the DEA hurdle is overcome, funding is the next
> challenge. Product
> stewardship would seem a logical choice, since reverse
> distributors
> could document which drug company manufactured the drug
> if it was in the
> original container and a chargeback could be issued.
> Original
> containment will not always be the case but could account
> for a majority
> of the returns. Otherwise we still haven't solved the
> issue of
> controlled substances being diverted, involved in
> poisonings, and
> entering the ecosystem. 
> 
>  
> 
> 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
> 
>   _____  
> 
> From: pharmwaste-bounces at lists.dep.state.fl.us
> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On
> Behalf Of Lucy
> Doroshko
> Sent: Monday, January 30, 2006 3:44 PM
> To: Andria Ventura; pharmwaste at lists.dep.state.fl.us
> Subject: [Pharmwaste] RE: Pharmwaste Digest, Vol 3, Issue
> 12
> 
>  
> 
> I know that DEA is becoming more aware of this problem
> and the fact that
> so many community programs are being asked by residents
> to manage their
> waste pharmaceuticals.  I like your idea, Andria.  What
> about different
> colored containers (dayglo purple or some such) so that
> patients would
> remember that the drug is a controlled substance?  I
> already know the
> negative part of that idea ... then the criminal element
> would more
> easily be able to identify discarded medication in the
> trash.  But, has
> the idea of different colored containers for controlled
> substances been
> put forth?
> 
>  
> 
> Lucy Doroshko, Recycling Specialist
> Pollution Prevention and Compliance Assistance Section
> MDEQ Environmental Science and Services Division
> 525 W. Allegan, One North
> PO Box 30457
> Lansing, MI  48909-7957
> 517/373-1322
> FAX:  517/241-0858
> doroshkl at michigan.gov
> 
>  
> 
> Check the DEQ Recycling Website at
> www.michigan.gov/deqrecycling
> 
> 
> >>> "Andria Ventura" <aventura at cleanwater.org> 1/30/2006
> 4:40 PM >>>
> 
> Regarding the issue of controlled substances, would it be
> possible to
> institute a policy requiring pharmacists to inform
> patients that a
> prescription is controlled, and therefore, not acceptable
> for drop off
> later
> on when they dispense the drug?
> 
> Andria Ventura
> Clean Water Action
> 