[Pharmwaste] re: setting up a take-back program

[Jackson, Jennifer]

A couple additional resources for starting a take-back program:

1) Bay Area report on week-long campaign with how-to info and lessons learned (apply to permanent take-backs as well) www.baywise.org/disposaldays 

2) Green Pharmacy Program at Teleosis Institute (with 14 take-back locations): www.teleosis.org -- technicians are trained to not take controlled meds.

If the collected meds will be handled by folks other than law enforcement, I'd suggest that your bins and outreach have a little disclaimer somewhere that states "No Controlled Substances" so that you don't knowingly accept them. This of course means that incidental controlled meds will be mingled, since folks generally don't know what a controlled med is, but at least you're not advertising that you take them. Our take-back events indicate about 10% of meds are controlled.

Agencies in the Bay Area also tried to get a waiver from the DEA to conduct a mail-back program using a reverse distributor. Although the DEA headquarters loved the concept (they felt it more secure than a bin in a pharmacy), their legal staff decided they can't provide a waiver without a change of the Controlled Substances Act. Statutory change requires a bill to be passed by Congress. You may be aware that Maine is implementing a mail-back program using the Maine DEA as the end recipient.

Good luck,

Jen Jackson  |  Pollution Prevention |  East Bay Municipal Utility District  |  510.287.0818 |  jacksonj at ebmud.com