[Pharmwaste] RE:landfill issue

[Matthew Mireles]

I believe most if not all law enforcement agencies in the U.S. dispose all
drugs (illicit and legal) by controlled, witnessed incineration approved by
the U.S. DEA and U.S. EPA.  From the Fourth Maine Benzodiazepines Study
Group International Conference in Portland, ME, October 2006, I learned that
law enforcement are collecting household medications (prescription and OTC)
when a death is investigated.  Apparently, this is a major source of
household medications, particularly for the elderly and chronically and
terminally ill people.  Closest family members and friends do not know how
much medications someone has at home.  State laws will differ, but most
states require some level of investigation of a death to certify that no
suspicious cause is associated with the deceased.  Check your state
regulations.  I haven't found any reference in law enforcement that
specifically classifies unused and expired medicines as medical or hazardous
waste.   

All medications found at the decedent's home are taken under custody by the
law enforcement as articles for possible crime evidence.  As soon as the
cause of death is determined (homicide, suicide, natural, etc.), these
medications (FCS and others) are immediately destroyed by incineration, on
site or by approved contractors.  Because of the great variety of
medications people stockpile in their homes, controlled incineration at temp
in excess of 1200 F is usually acceptable and preferred.  It would be too
costly and inefficient to sort and separate each medication collected from
home and proper neutralize them chemically or otherwise.  Someone should
also check about the temp for halogenated compounds in pharma products.

Technically, there is a legal issue of possession if you have any controlled
substance or prescription meds that have not been prescribed to you by a
physician.  After someone dies, this can be problem.  Poison Control and
most local pharmacies recommend flushing down the toilet or sink and not
throwing narcotics with household trash for "safety".  

The technology for better and safer incineration that limits particulates
into the atmosphere exists and should be considered for small- to
large-scale systematic disposal and thorough destruction expired and unused
medications.  This system already is in place by healthcare institutional
disposal through reverse distributors.  These distributors conduct detailed
inventory and sorting at the level that most of us cannot perform.  Hence,
we only at best report weight (pounds) or a volume by proxy (buckets or
hefty bags, etc.).  

One last comment, manual sorting creates an occupational exposure that would
concern OSHA.  Be sure occupational health and safety guidelines, training,
and policies are in place.  

We have set up the Unused and Expired Medicines (UEM) Registry based in
Houston, Texas, and we have begun to collect the basic data on the UEM. We
are not involved directly with actual collection and destruction of the
drugs.  So far, all the collected drugs in our database, I believe, were
incinerated by law enforcement.  We provide assistance to other
organizations and communities that are trying to implement a systematic
collection program by providing educational materials and a simple home
inventory form to list UEM.  The completed forms can be turned in along with
the UEM.  We can collect the data and use our standardized coding to enter
the data into the UEM Registry for analysis and provide a summary report.


Matthew Mireles, PhD, MPH
President and CEO
Community Medical Foundation for Patient Safety
www.communityofcompetence.com

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Jackson,
Jennifer
Sent: Tuesday, February 06, 2007 3:15 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE:landfill issue

In the San Francisco Bay Area we do not have consensus from the solid
waste companies and agencies that trash is the solution. My
understanding is that there are several reasons for this. First, manual
sorting happens at some landfills and transfer stations, opening the
issue of diversion. Second, some areas still have not-so-modern
landfills located adjacent to surface water bodies. And last, leachate
that is collected from even the modern landfills is typically off-hauled
to wastewater treatment plants, so if there are pharms in the leachate,
we are just putting the issue of treatment back into sewage treatment's
court.

Jen Jackson | East Bay Municipal Utility District | 510-287-0818


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