[Pharmwaste] Starting a take-back program

[Lauer, Michelle]

Hello:
  	 I am new to the list-serve and on the environmental stewardship
committee of my hospital. Recently, we received a grant from DNREC to
start a medication take back program for the community and planned to do
so at three out-patient hospital pharmacies. The plan is to purchase
secure, locked bins and for the public to come during pharmacy hours and
dispose of meds. We did not want to exclude controlled substances, as
there would really be no one continuously monitoring what was dropped in
the bins, and of course, we want to collect as much as possible in order
to divert from going down the drain. The DEA has stepped in, with
controlled substance act in hand, and said "NO" -  stating that even if
we said, "No controlled substances" the public would not be able to
distinguish and therefore not an option. Also, that controlled
substances cannot be returned to a 'registrant', although no one in the
pharmacy would be handling the meds. 
  	I am seeking any advice regarding moving forward with our
program. How have other systems or communities navigated this roadblock?
Also, what, if anything, is being done at this time to amend the
controlled substance act? What is the role of the EPA in interfacing
with the DEA to advocate for providing waivers in order to decrease the
introduction of all pharmaceuticals into water? 
Thanks!

Michelle Lauer, RN, BSN, BC
Patient Care Coordinator - Psychiatry
428-2117 or pager # 884-9440



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