[Pharmwaste] NASCA presentation

Tue Nov 14 22:30:22 EST 2006

Hi Ross,

The state controlled substances representatives cannot act beyond what
DEA is willing to authorize. DEA representatives attended as speakers
and discussed primarily other issues. In discussing the issue of
consumer take back options with John Cavendish at DEA prior to the
conference, I did not get any sense of changes to the procedures to
which you refer, but that was not my primary reason for contacting him.
You might want to check with Dr. Steve Gressitt in Maine to see if any
additional guidance was provided at his Consumer Take Back conference
which was held Oct 23/24. There was no discussion at the NASCSA meeting
that I am aware of regarding alternatives to incineration regarding
rendering the drugs non-recoverable. My seminar was the only one focused
on consumer take back and that was primarily to bring them up to speed
on EPA issues and propose the reverse distribution model. 

I'm sorry I don't have any additional information for you. 

Best regards, 

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: Bunnell, Ross [mailto:Ross.Bunnell at po.state.ct.us] 
Sent: Tuesday, November 14, 2006 2:27 PM
To: Charlotte A. Smith
Cc: pharmwaste at lists.dep.state.fl.us; Tenace, Laurie
Subject: RE: [Pharmwaste] NASCA presentation

Charlotte:

I was particularly interested in the attendees' expressed willingness to
consider policy and/or regulatory changes to DEA rules as they relate
to:

(1)  collection of individual consumers' old/unwanted controlled
substances at local pharmaceutical collection events.  In Lynn
Rubenstein's collections in New England through NERC, arrangements had
to be made individually to ensure that state and federal controlled
substance programs and local law enforcement were on board, and our
first collection in CT almost got scuttled at the last minute due to an
issue that arose with our state's controlled substance division.  And,

(2)  alternatives to "witnessed destruction" other than drain disposal.
I know the controlled substance folks have bought into treatment
technologies such as documented incineration as an alternative, but it
seems that it has to be worked out on a case-by-case basis.  It would
help all of us if nationwide protocols could be worked out for any/all
acceptable environmentally appropriate alternatives to drain disposal.

If you can, please "reply to all," so the Pharmwaste ListServe folks can
benefit from your reply as well.  Thanks!

- - Ross.

________________________________

From: Charlotte A. Smith [mailto:csmith at pharmecology.com] 
Sent: Monday, November 13, 2006 11:24 PM
To: Bunnell, Ross
Subject: RE: [Pharmwaste] NASCA presentation

Hi Ross,

Nice to hear from you!  DEA is certainly interested in the model I
discussed regarding consumer take back programs through reverse
distributors, which would require a change in the DEA regulations. I
also submitted draft language for such a change. While they haven't had
a chance to review it seriously yet, I have hopes. With respect to
hospital disposal, I did not specifically address that other than review
the options, which include sewering, transfer to a hazardous waste
vendor who is also a DEA registrant, or transfer to a reverse
distributor who is a DEA registrant. Most of the participants are state
controlled substance folks who must follow the DEA lead first. DEA did
present and I did get some time with them, but it focused on consumer
take back. They are still very adamant on the non-recoverable piece. I
doubt this addressed your concerns, did it? 

Best regards, 

Charlotte A. Smith, R. Ph., M.S., HEM
President
PharmEcology Associates, LLC
200 S. Executive Drive, Suite 101
Brookfield, WI 53005
Phone: 262-814-2635
Fax: 414-479-9941
csmith at pharmecology.com

________________________________

From: Bunnell, Ross [mailto:Ross.Bunnell at po.state.ct.us] 
Sent: Monday, November 13, 2006 10:51 AM
To: Charlotte A. Smith
Cc: Tenace, Laurie; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] NASCA presentation

Charlotte: 

I finally got the time to go through your NASCA presentation.  I'm
curious to know how your presentation was received.  Was there some
willingness to work with us on the disposal issue, or just lots of
skepticism?

- - Ross Bunnell, CT DEP 
Bureau of Materials Management and Compliance Assurance 
Waste Engineering & Enforcement Division 
79 Elm Street 
Hartford, CT 06106-5127 
Tel. (860) 424-3274  Fax (860) 424-4059 

-----Original Message----- 
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us
<mailto:pharmwaste-bounces at lists.dep.state.fl.us> ] On Behalf Of Tenace,
Laurie

Sent: Wednesday, November 01, 2006 9:36 AM 
To: pharmwaste at lists.dep.state.fl.us 
Subject: [Pharmwaste] NASCA presentation 

http://www.nascsa.org/Folder2/confer2006.htm
<http://www.nascsa.org/Folder2/confer2006.htm>  

Scroll to see Charlotte Smith's presentation to the National Association
of State Controlled Substance Authorities, if interested. Cathy
Gallagher's presentation from DEA is also pertinent.

Laurie J. Tenace 
Environmental Specialist 
Florida Department of Environmental Protection 2600 Blair Stone Road, MS
4555 Tallahassee, Florida 32399-2400 
PH: (850) 245-8759 
FAX: (850) 245-8811 
Laurie.Tenace at dep.state.fl.us  

view our mercury web pages at: 
http://www.dep.state.fl.us/waste/categories/mercury/default.htm
<http://www.dep.state.fl.us/waste/categories/mercury/default.htm>  

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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