[Pharmwaste] Long term care drug disposal -

Fri Oct 12 09:36:44 EDT 2007

Michele:

I am working with the same LTC issue here in Kansas.  Our Kansas Department
of Health and Environment, has publish a guidance document,
http://www.kdheks.gov/waste/guidance/sw07-01.pdf, that applies to the public
and most LTC facilities.  It documents a hierarchy for pharmaceutical waste
management that lists drain-disposal as the very last option.  

Certainly maximizing the use of return processing programs is the preferred
option, but in LTC it is not an option for controlled substances.  I am
working with our Kansas Board of Pharmacy (and the DEA) to determine if
these non-RCRA controlled substances can be "wasted" or disposed of using an
absorbent like kitty liter and then go to the trash.  If I understand it
correctly, DEA's concern is that the controlled substances are destroyed so
that they are "non-recoverable."   Although land filling is not the best
option, it is a legal, practical, and economic option, that keeps these
excess and expired pharms from directly entering our waterways.

If you are not already aware of it, EPA is planning a teleconference on this
topic next week.  For more information contact
Hessenauer.Meghan at epamail.epa.gov.  Kansas plans to host a LTC pharmacy
waste management Web cast Dec 13.  To learn more about the Kansas program go
to http://www.sbeap.org/publications/Pharmaceutical/index.php. 

Nancy J. Larson, RS

Director, KSU Pollution Prevention Institute  

Small Business Environmental Assistance Program
316/722-7721 ext. 104
800/578-8898
www.sbeap.org
 <mailto:NLarson at ksu.edu> NLarson at ksu.edu 

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  _____  

From: Price, John L. [mailto:John.L.Price at dep.state.fl.us] 
Sent: Tuesday, October 09, 2007 9:23 AM
To: Bunnell, Ross; Michele Berger; pharmwaste at lists.dep.state.fl.us
Cc: Walker-Coleman, Lauren J.; Redig, Michael
Subject: RE: [Pharmwaste] Long term care drug disposal - still need
Floridainformation?

Michele: I have not seen any more Pharmwaste chatter on your post. If you
have not found the information on Florida's regulations and guidance, please
contact me.  We do have guidance that discourages disposal by flushing and
encourages other appropriate disposal (see
http://www.dep.state.fl.us/waste/quick_topics/publications/shw/meds/DEPMedic
ationDisposalFlyer111706Final.pdf).  This guidance is written for household
users and may not apply to your facility's situation.  We also allow
management of unwanted medications from commercial facilities under a
reverse distribution system and managed as universal waste (see
http://www.dep.state.fl.us/waste/quick_topics/rules/documents/62-730.pdf,
specifically 62-730.186). 

As Ross correctly observed, there may be other regulations, guidance, etc.
that is specific to the local wastewater authority that receives wastewater
from your facility. 

Please let me know what information you need and we'll hook you up with the
appropriate information resources.

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

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Thank you in advance for completing the survey.

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Bunnell, Ross
Sent: Friday, September 14, 2007 4:05 PM
To: Michele Berger; pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Long term care drug disposal

Michele:

If you haven't done so already, check with the Florida DEP and the local
sewer authority to see what their rules are concerning sewage discharges.

Here in CT, any discharge of a substance other than septage to the sewer
requires approval from the local sewer authority AND a permit from the CT
DEP.  For many years, our state permitting staff were unaware of this
practice, until recently, when a release from a long-term care facility
caused the local wastewater treatment plant to fail.  What happened was that
an adult diaper shredder at the faculty became clogged, and a large amount
of effluent from the facility backed up in it; when the clog was cleared,
the pharmaceutical-laden sewage hit the treatment plant all at once and
killed the beneficial bacteria that aid in the digestion of the sewage.

Following this incident our water permitting folks have become very
interested in the issue of disposal of drugs down the drain, and are working
with other staff at the CT DEP to stop the practice statewide.

Another point to consider:  if any of the long-term care facilities are NOT
on local sewer, but are instead discharge their sewage to an engineered
septic system, there may be rules in Florida regarding the types of wastes
that can be discharged to such systems.  Here in Connecticut, such systems
may only receive septic and associated wastewaters, and not chemical wastes
of any kind (e.g. pharmaceuticals).

- - 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 

Disclaimer:  Any views expressed in this email represent only the sender's
personal opinion based on his knowledge and experience with the DEP, and in
no way should be considered a formal ruling by the Department.  It is always
the obligation of a generator or other handler of waste to be familiar with
and to comply with all applicable state and federal requirements.

  _____  

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Michele
Berger
Sent: Friday, September 14, 2007 3:33 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Long term care drug disposal

When I started at my long term care pharmacy, all discontinued drugs were
being flushed.  I immediately got in touch with a reverse distributor to
have them disposed of properly.  For many months I have been encouraging the
owner of our pharmacy to become more pro-active in discontinued drug
disposal in our homes, including narcotics.  Yesterday a surveyor was at one
of our homes and insisted that our policies be changed to state "All
discontinued narcotics are to be flushed down the toilet".  After I have the
owner so close to making the disposal a consultant pharmacist
responsibility, I have been foiled again.  I understand it isn't easy to
change a set idea but when options are there and you aren't allowed to use
them it becomes extremely frustrating!  

Can anyone tell me where to find, in Florida law, that flushing meds down a
toilet is more regulated than a DEA transfer?  Not to mention better for the
environment!  

Michele Berger

  _____  

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