[Pharmwaste] RE: Texas Pharmaceutical Disposal Programs
Matthew C. Mireles
mirelesmc at earthlink.net
Fri Aug 7 22:34:32 EDT 2009
Those are good points Virginia. I believe in absence of any measureable leadership or guidance from federal agencies, it was open to how we named our Registry and Directory. Yes, we are aware of most of the programs you mentioned and we try to make every attempt to contact the organizers with our Annual Survey. Since this is a voluntary national survey to drug take-back programs, we can't make anyone complete the form and return it to us. We usually make note of the program but we can't include it in our National Directory. Completion of the survey and successful transmission back to our office for coding constitute consent to be listed on our National Directory. We don't list any program that the organizer(s) chooses not to participate in our survey. Several don't want to be listed because it was just a one-time, pilot study or the program was a failure.
We also check our data with the DEA. I don't believe the EPA has anything official about drug take-back programs except those that were funded. We approached the survey as a scientific data collection, not just listing the name and location. We go into a little description of the program, especially the involvement of law enforcement and sharing of UEM data. We hope to encourage more programs to collect usable data based on our standardized instrument so they can be entered into our National Unused and Expired Medicines Registry. I don't think any federal agency has a similar national database on UEM. I know so because we provide reports to the FDA, EPA, DEA, ONDCP, state governments, and research groups around the country. As a matter of fact, I just finished our keynote presentation to the EPA Region 6...a talk on pharmaceuticals and personal care products. This is a pretreatment group, and most members are not too aware of the current issues and discussion of UEMs. I think we educated this EPA group.
I just returned from DC for a discussion of a high-level proposition to create a regional multi-state take back system. There is a growing interest to standardize or at least conform drug take-back programs in the US. Polymorphism of these programs is causing some great deal of concern with a number of risk, such as legality , safety, and compliance to federal regulations. As this movement grows, I imagine one or two national models would emerge. Any other model of drug take-back programs would end. In additional to our National Unused and Expired Medicines Registry, we publish the National Directory of Drug Take-Back and Disposal Programs. Info from the latter comes directly from our survey and is analzyed and included in summary tables for comparison. This is the info we provided to the folks in DC.
In a few weeks we post electronically the most updated list of take-back programs. This list will be posted at 4 websites: Maine Benzo, Community Medical Foundation, Product Stewardship Institute, and NNEPC. We are in the process of expanding our Community of Partners to include NPCIE, NADDI, Poison Centers, and others to post the same list.
If anyone knows of a drug take-back program in your neighborhood and community, please, please let us know. Or tell the organizer to contact us. We will invite them to complete our Annual Survey and include them in our National Directory. The participants on the "pharmwaste listserv" based on Florida are the best when it comes to dissemination of info! Response rate to our survey was significantly increased when the survey was published on the pharmwaste listserv. We studied several listservs to evaluate how info about UEMs and drug take-back programs is diffused and shared among a community of interested professionals, researchers, policy makers, advocates, and even government workers.
The top three listservs for this kind of discussion and information are:
1. pharmwaste listserv !!!!
2. Maine Benzo group
3. Product Stewardship Institute
Virginia, if you are in touch with drug take-back programs in your area, please join your EPA colleagues in notifying us or mentioning our group to them. Many start up programs can benefit from our technical assistance with program implementation and data collection. We are still trying to move people away from reporting number of boxes, barrels, and pounds.
Incidentally, the presentation to the EPA covered the exact drug name, type, quantity (pill count), environmental hazard and risk assessment (based on the Sweden environmental classification system; I don't think the EPA has developed a environement classification system for pharmaceuticals that is usable). Several years ago, Sweden began systematic tissue sampling fish and amphibians for adverse effects from drugs in the water. Through ODEC's new REACH principle (Restriction, Evaluation, Assessment of (dangerous) Chemcials), drug companies must demonstrate that a new drug is environmentally safe before it goes into market. I believe it may be the opposite in the US where we have to show that a chemical or drug is dangerous before it can be removed. Interestingly, the EPA fought fiercely against the adoption and implementation of REACH in the EU.
Is anyone more knowledgeable about REACH and care to elucidate this EU policy and how it will have an impact on our pharmaceutical export to EU and the work of the US EPA? This may be a job for that feisty senator (Boxer?) who sits on the environmental safety committee and EPA and learned about drugs in the water when she read the AP story in her local newspaper. She should join our pharmwaste listserv and stayed informed.
Therefore, Virginia, when the EPA starts collecting systematic data on UEMs and conducting annual surveys of drug take-back program and compiling them in some accessible database(s), I'll be happy to turn over our National Registry and National Directory to you. Right now, think of our programs as place holders until something more wonderful comes along. If you wish to have a copy of our National Directory, we now can invoice you directly and take your payment online.
Matthew Mireles
-----Original Message-----
>From: Thompson.Virginia at epamail.epa.gov
>Sent: Aug 7, 2009 6:50 AM
>To: "Matthew C. Mireles" <mirelesmc at earthlink.net>
>Subject: Re: [Pharmwaste] RE: Texas Pharmaceutical Disposal Programs
>
>Matthew,
>Does your national directory include the events that have been held in
>the Mid-Atlantic region, including Pennsylvania, Delaware, Virginia, &
>West Virginia? There have been about a dozen or so in the past 18
>months--that I'm aware of, and likely some I'm not aware of. And does
>it include all of the collection events that were held as part of the
>Great Lakes "1 Million Pills" effort around Earth Day in 2008? It's
>very difficult to keep track of all of the events that go on around the
>country, because they don't all get reported nationally. In fact, even
>though I'm the regional coordinator on many of these pharm issues, I
>find myself surprised to learn of some fairly local efforts. If you
>don't include all of the events and from all of the states that have
>held them, I would caution about saying "The Directory lists all the
>programs in the nation" or calling it a National directory. Thank you.
>
>Virginia Thompson
>Sustainable Healthcare Sector Manager
>Office of Environmental Innovation (3EA40)
>US Environmental Protection Agency Region 3
>1650 Arch Street, Philadelphia, PA 19103
>Voice: (215) 814-5755; Fax (215) 814-2783
>thompson.virginia at epa.gov
>
>
>
>
>
>
> Re: [Pharmwaste] RE: Texas Pharmaceutical Disposal Programs
>
>
> Matthew C. Mireles
> to:
> Tony Madruga, McKinley,Gena,
> 'pharmwaste at lists.dep.state.fl.us'
> 08/05/2009 11:14 AM
>
>
>
>
> Sent by:
> pharmwaste-bounces at lists.dep.state.fl.us
> Cc:
> "john.r.prince at dvault.com", easmith, "Karen Bartkowiak
> (karen.bartkowiak at dvault.com)"
> Please respond to "Matthew C. Mireles"
>
>
>
>
>
>
>
>
>
>Gena,
>We run the National Unused and Expired Medicines Registry and conduct an
>annual survey of all the drug take-back programs in the US. We publish
>the survey data in our National Directory of Drug Take-Back and Disposal
>Programs. The Directory lists all the programs in the nation. Please
>contact me if you wish to have a copy.
>
>Our group is based in Houston, but most of our work in drug return
>system are in Maine and CA. We also are consulting with federal
>agencies in designing a national drug take back system.
>
>There are a few take-back programs in TX (Plano, Dallas area). One is
>beginning in Corpus I believe. All of these are small community-based
>programs. In Houston, we ran one pilot study with senior citizens. One
>for-profit company in Houston has a mail-back system set up with
>shipping kits and an incineration unit in Carthage TX. Another large
>company in anticipation for a business venture has purchased a large
>industrial incineration facility in Chamber Co.
>
>Since we provide technical assistance in designing these programs around
>the country, we highly encourage the involvement of law enforcement
>whenever there's a possibility of collecting controlled substances.
>Most of the programs in TX mentioned above all have law enforcement
>involvement.
>
>We also publish a comprehensive manual of procedures for drug take back.
>This manual has been selected as the official reference of instructions
>for an upcoming international conference on drug disposal in Maine
>(mainebenzo.org).
>
>As far as partnership between city govt and retail pharmacies in TX, we
>have not seen this in our survey. CA, OR, and WA use this model for
>their take back system. In TX, the most promising initiative and
>partnership are coming from the Poison Center (Lubbock, Galveston, etc.)
>You may want to join the listserv and get involved right away. My
>advice for now is to proceed carefully. The DEA is keeping a close eye
>on TX. Our programs are in compliance with DEA regs.
>
>I hope my info is useful. Please contact me if you have questions. By
>the way, I worked at UTMB before I move to Houston for grad school.
>
>
>
>Matthew C. Mireles, PhD, MPH
>President and CEO
>Community Medical Foundation for Patient Safety
>6300 West Loop South, Suite 288
>Bellaire, TX 77401
>832-778-7777
>www.communityofcompetence.com
>
>
>
>
>
>-----Original Message-----
>From: Tony Madruga
>Sent: Aug 4, 2009 4:18 PM
>To: "McKinley, Gena" , "'pharmwaste at lists.dep.state.fl.us'"
>Cc: "john.r.prince at dvault.com" , "Karen Bartkowiak
>(karen.bartkowiak at dvault.com)"
>Subject: [Pharmwaste] RE: Texas Pharmaceutical Disposal Programs
>
>Hi Gena,
>
>I am not aware of any current programs in your area, however we can
>provide all of your unattended collection unit needs through our sister
>company Take Back Express.com.
>
>More information can be found at: http://www.takebackexpress.com
>
>Regards,
>
>Tony O. Madruga
>President
>dVault® Companies, Inc.
>
>
>www.dvault.com
>
>voice: 720.895.1908
>fax: 720.895.1909
>
>tony.madruga at dvault.com
>
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>This email and any files transmitted with it are confidential
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>
>From: pharmwaste-bounces at lists.dep.state.fl.us
>[pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of McKinley, Gena
>[Gena.McKinley at h-gac.com]
>Sent: Tuesday, August 04, 2009 2:01 PM
>To: 'pharmwaste at lists.dep.state.fl.us'
>Subject: [Pharmwaste] Texas Pharmaceutical Disposal Programs
>
>Hello!
>
>I am in the process of working on a BMP guide for the management of
>pharmaceutical waste, and am looking for example programs in the State
>of Texas. I am also interested to know if any pharmacies in the State
>of Texas have partnered with municipalities in the collection of
>pharmaceuticals. Please contact me if you have any information.
>
>Thanks!
>Gena
>
>Gena McKinley, MPH
>Environmental Planner
>Houston-Galveston Area Council
>Tel: 713-993-4529
>Fax: 713-993-4503
>www.RecycleInfo.org
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