[Pharmwaste] Guidance - Pharm waste disposal

Barry Fernandez Barry at clean-fuels.net
Fri Sep 14 09:49:03 EDT 2007


Dan:

A couple of things:
1. By "all discontinued meds" I'm assuming this means controlled
substances.  Non-controlled substance pharmaceutical waste would be
regulated by EPA and your state environmental agency.
2. When you say "state law" which agency are you talking about? That's
important to know.
3. HHW events usually have to be DEA or law enforcement sanctioned in
order to accept controlled substances since destruction has to be
witnessed.  Typically the DEA only allows acquisition of controlled
substances between registrants (i.e. retail pharmacy, reverse
distributor, etc.) or dispensing to a prescribed patient.  There are no
provisions for return to a pharmacy by a patient unless recalled by the
manufacturer.  Long-term care facilities act in a custodial capacity and
usually aren't registered.

Florida has a brochure for the disposal of household medications.
Emphasis on "households" and "Florida":
http://www.dep.state.fl.us/waste/quick_topics/publications/shw/meds/DEPM
edicationDisposalFlyer111706Final.pdf

DEA Office of Diversion Control has a website.  Not much in the way of
disposal of the nature you are describing, but some good information
there.  Perhaps you can track down the field officer for your region and
seek additional guidance:  http://www.deadiversion.usdoj.gov/

Please let us know how you make out.  It's always interesting to see how
things are done elsewhere.

Regards,
Barry

Clean Fuels of Florida, Inc.
D. Barry Fernandez, President
2635 NE 4th Avenue
Pompano Beach, FL 33064
Tel:  954-791-9588
Fax: 954-791-9366
Cell:  305-216-4941
Toll Free: 800-725-8711
barry at clean-fuels.net
www.clean-fuels.net



-----Original Message-----
From: DNKing at lincoln.ne.gov [mailto:DNKing at lincoln.ne.gov]
Sent: Thursday, September 13, 2007 5:26 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Guidance - Pharm waste disposal


Hello:

State law in Nebraska requires that all discontinued meds for nursing
home residents be destroyed on the site of the long-term care facility.
Currently, I believe that these meds are being flushed?  Can you think
of a way to render the meds unusable, so that they can be safely put
into the trash? (What can they be mixed with that would not make them a
hazardous waste or be noted as "treatment"?)

Also, what about household hazardous waste-like events, can
pharmaceuticals be rendered unusable on-site at a mobile collection?
I've heard yes and no.

Finally, I'm having a challenging time finding any DEA guidance on the
issue?

Any and all info regarding on-site destruction is appreciated.

Thanks,

Dan N. King
Environmental Health Educator II
Environmental Public Health Division
Lincoln-Lancaster County Health Department office 441.8084
dnking at lincoln.ne.gov www.lincoln.ne.gov (keyword: household)

"Waste is a tax on the whole people."
- Albert W. Atwood
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