[Pharmwaste] Northfield owner arrested

Lucy, Burke blucy at CIWMB.ca.gov
Fri Jun 19 14:50:19 EDT 2009


This is a timely topic - I'm the sharps and pharmaceuticals disposal specialist for the California Integrated Waste Management Board - one of those state EPA agencies on pharmacists' list to contact - at least in California - to ensure they meet proper guidelines.

In California, we don't have anything explicitly written in our law stating pharmacists can collect pharmaceuticals (or sharps) but it is in the language of one bill (SB 26: http://www.leginfo.ca.gov/cgi-bin/postquery?bill_number=sb_26&sess=CUR&house=B&author=simitian) that was shelved until next year along with many others due to our budget crunch.  However, I was just talking with representatives of our Board of Pharmacy and Department of Public Health and they both emphatically encouraged getting the word out to all of our potential collection sites, including pharmacies, to say the pharmaceutical collection Criteria and Procedures document that was hammered out over the past year, is the best officially sanctioned guideline we have in California.

In case anyone is interested, you can find a link to it (along with other background information) here:

www.ciwmb.ca.gov/HHW/PharmWaste/ModelProgram

Some highlights of the guidelines are:

- No cost to the customer
- Signage on the collection bin such as no controlled substances (without a sworn law enforcement officer present)
- Signage directing pills to be removed from bottles and placed in a sealable plastic bag - liquids stay in their bottles
- Bins located at pharmacies shall have a two key security system--one in the possession of the collection site's designated responsible person and the other in the possession of the licensed hauler who will pick up the contents for appropriate destruction.
- Once a collection bin becomes full, no more pharmaceutical waste can be accepted from consumers (e.g., locked from public use) by the collection site until a waste hauler has removed the pharmaceutical waste, and re-stocked the collection device with an empty container.

We're not in the business of recommending particular collection bin vendors but I would like to provide very straightforward step by step guidelines based on these Criteria and Procedures, and include links to collection bins that comply with our guidelines.  So far, I am aware of the bins from Take Back Express (parent company is dVault) with a "Dual Posi-Lock Key Option" from here: http://www.takebackexpress.com/product_p/dvdc0080-sld-4.htm.  I also know they have a variety of sizes such as the Jumbo Sharps Collection unit with a wheeled locked tote (25"W x 50"H x 27"D).  They also come standard with a window that makes it easier to tell if the bin is getting full so that the hauler can be contacted in time and the bin wouldn't have to get locked from public use.  We also have a medical waste transporter, Curbside Inc. (www.curbsideinc.com), who has a two-key system.

If anyone knows of another good two-key bin system, ideally that also has a window in it, please let me know.

Thanks,

Burke


Mr. Burke Lucy
Integrated Waste Management Specialist
1001 I Street, PO Box 4025
Sacramento, CA 95812
blucy at ciwmb.ca.gov
916.341.6484

-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Volkman, Jennifer
Sent: Friday, June 19, 2009 9:55 AM
To: Nicole Gattas; JenniferVolkman; AllenGilliam; pharmwaste at lists.dep.state.fl.us; StevanGressitt
Cc: Alvin Simmons; mirelesmc at earthlink.net
Subject: RE: [Pharmwaste] Northfield owner arrested

Yep, that's been my experience, we have a lot of genuinely concerned pharmacists interested in collecting.  I think we're saying that reverse distributors could make a mess out of the legitimate and compliant efforts by blowing it at the end.  I'm setting up a meeting with our pharmacy board, DEA, pharmacy association to go over these issues and hopefully get together guidance specific for MN collections.

________________________________

From: Nicole Gattas [mailto:nmpeterse at yahoo.com]
Sent: Fri 6/19/2009 11:45 AM
To: JenniferVolkman; AllenGilliam; pharmwaste at lists.dep.state.fl.us; StevanGressitt
Cc: Alvin Simmons; mirelesmc at earthlink.net
Subject: RE: [Pharmwaste] Northfield owner arrested


List,
I'm a pharmacist that developed and coordinated a take back program in 20 chain stores (Schnucks) in St. Louis (MO and IL). We received quite a bit of press for our program that was supported by a grant from the EPA, and had many pharmacies calling me to ask how they could set it up.  The demonstration project is now over, and we are currently in data collection, so have not published results as of yet.

So I'd like to comment from my perspective as a pharmacist...
The pharmacists interested in this program genuinely want to do this as a value added service to assist with patient safety and help with environmental concerns.  They do not want to take back drugs to re-distribute them.  (I have only heard of one pharmacist that was doing something like this with samples from physicians offices, obviously against the law.)

However, most state pharmacy practice acts do not discuss this, and within most colleges of pharmacy, we don't teach about pharmaceuticals in the environment, disposal, hazardous waste regulations, etc... normally within the curriculum. (I have heard that Midwestern in Chicago offers an elective.)  Therefore, a pharmacist interested in this area currently has no easily accessible information on how the process should or must work, and may rely on information from a reverse distributor.

When chains or pharmacists have asked me, I have recommended they NOT try to implement a take back program into their pharmacy unless they have a champion that is willing to get approvals from their board of pharmacy, state DEA, state EPA, etc and become an expert in the area.  Many of them thought... I'll just take them back and send them back through my distributor or incineration company, when we on this list know it is not that simple.

I guess my main point is: pharmacists (and other health care professionals) are genuinely concerned about this issue, but grossly undereducated in my opinion.  We need to address this at different levels including curriculum, trade journals, and primary literature. While we've recieved press on our program, no one has published the down and dirty details, etc that go along with setting up a program like this and help pharmacists realize laws and regulations that are involved.

Hopefully we will be publishing results from our project soon!

Thanks for reading my 2 cents!
Nicole Gattas, Pharm.D., BCPS


Nicole M. Gattas, Pharm.D., BCPS
Assistant Professor of Pharmacy Practice
St. Louis College of Pharmacy
pager: (314) 253-2294
voicemail: (314) 446-8555
cell: (314) 504-1202
email: nmpeterse at yahoo.com <mailto:nmpeterse at yahoo.com>


--- On Fri, 6/19/09, Gressitt, Stevan <Stevan.Gressitt at maine.gov> wrote:



        From: Gressitt, Stevan <Stevan.Gressitt at maine.gov>
        Subject: RE: [Pharmwaste] Northfield owner arrested
        To: "Volkman, Jennifer" <Jennifer.Volkman at state.mn.us>, "Gilliam, Allen" <GILLIAM at adeq.state.ar.us>, pharmwaste at lists.dep.state.fl.us
        Cc: "Alvin Simmons" <alvsim4317 at gmail.com>, mirelesmc at earthlink.net
        Date: Friday, June 19, 2009, 11:17 AM


        I just had another conversation yesterday with a pharmacist who who
        blithely told me he knew what he was doing with his take back was
        probably against the law but "so what I'm doing the right thing."

        It was so "in my ear" that I just decided not to even comment.

        There is a very very very long way to go yet.



        Stevan Gressitt, M.D., Medical Director
        Office of Adult Mental Health Services
        Department of Health and Human Services
        Marquardt Building, 2nd Floor
        11 State House Station
        32 Blossom Lane
        Augusta, ME  04333-0011
        Ph: (207)287-4273
        Fax: (207)287-1022
        Cell Phone: (207) 441-0291
        E-Mail : stevan.gressitt at maine.gov <http://us.mc822.mail.yahoo.com/mc/compose?to=stevan.gressitt@maine.gov>
        http://www.maine.gov/dhhs/mh/

        Confidentiality Notice: This e-mail message, including any attachments,
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        -----Original Message-----
        From: Volkman, Jennifer [mailto:Jennifer.Volkman at state.mn.us <http://us.mc822.mail.yahoo.com/mc/compose?to=Jennifer.Volkman@state.mn.us> ]
        Sent: Friday, June 19, 2009 12:04 PM
        To: Gilliam, Allen; pharmwaste at lists.dep.state.fl.us <http://us.mc822.mail.yahoo.com/mc/compose?to=pharmwaste@lists.dep.state.fl.us>
        Cc: Alvin Simmons; Gressitt, Stevan; mirelesmc at earthlink.net <http://us.mc822.mail.yahoo.com/mc/compose?to=mirelesmc@earthlink.net>
        Subject: RE: [Pharmwaste] Northfield owner arrested

        We had a "reputable" reverse distributor here in MN that told a pharmacy
        they'd take everything from their household pharm collection and manage
        it for free as a value added service.  Well, we know none of those
        pharms can be redistributed and a portion of them will be hazardous and
        a portion will be controlled substances.  I was disappointed at their
        lack of knowledge of the HW and DEA regulations.  The pharmacist is one
        I've worked with over the past few years and knew the regulatory issues
        and that the deal sounded too good to be true. She called and we
        clarified that the reverse distributor could not do that, but other
        pharmacists that are pretty comfortable with their RDs might not see a
        red flag here.  I think there is plenty of work that needs to be done to
        ensure that RDs understand the regulatory issues so they don't end up
        getting fined for acting as unpermitted RCRA transporters or facilities.
        It is definitely something to go over with those who are doing HH pharm
        collection in your states, we don't want this issue to cut us off at the
        knees as Allen notes.

        Another RD we looked at was doing the same basic thing--taking all,
        sorting and sewering what couldn't be legitimately redistributed.  They
        are doing a much better job now with some technical assistance.  I'm not
        sure how these entities are licensed, maybe through the state pharmacy
        board?  I'm going to check on that to see if we can get them some
        guidance because as far as I know we're 0 for 3 with these operations in
        MN.

        ________________________________

        From: pharmwaste-bounces at lists.dep.state.fl.us <http://us.mc822.mail.yahoo.com/mc/compose?to=pharmwaste-bounces@lists.dep.state.fl.us>  on behalf of Gilliam,
        Allen
        Sent: Fri 6/19/2009 7:08 AM
        To: pharmwaste at lists.dep.state.fl.us <http://us.mc822.mail.yahoo.com/mc/compose?to=pharmwaste@lists.dep.state.fl.us>
        Cc: Alvin Simmons; Gressitt, Stevan; mirelesmc at earthlink.net <http://us.mc822.mail.yahoo.com/mc/compose?to=mirelesmc@earthlink.net>
        Subject: RE: [Pharmwaste] Northfield owner arrested



        I've heard this is not uncommon even at some of the pharmacies who are
        participating in a customer "take-back" program.  Many more stories like
        this come out, the DEA's gonna put a tight plug on the legit programs, I
        fear.

        -----Original Message-----
        From: pharmwaste-bounces at lists.dep.state.fl.us <http://us.mc822.mail.yahoo.com/mc/compose?to=pharmwaste-bounces@lists.dep.state.fl.us>
        [mailto:pharmwaste-bounces at lists.dep.state.fl.us <http://us.mc822.mail.yahoo.com/mc/compose?to=pharmwaste-bounces@lists.dep.state.fl.us> ] On Behalf Of Jennifer
        Crittenden
        Sent: Wednesday, June 17, 2009 11:57 AM
        To: pharmwaste at lists.dep.state.fl.us <http://us.mc822.mail.yahoo.com/mc/compose?to=pharmwaste@lists.dep.state.fl.us>
        Subject: [Pharmwaste] Northfield owner arrested


        Owner of Northfield drug disposal service now facing charges

        Link:
        http://www.startribune.com/local/south/45486592.html?elr=KArksi8cyaiUgOa
        hccyiUiacyKUnciatkEP7DhUs

        The owner of a Northfield company that collects outdated, recalled or
        excess pharmaceuticals has been indicted in federal court for allegedly
        diverting prescription drugs for sale on the street.

        Mark Andrew Goetz, 40, of Prior Lake, was charged Tuesday with illegally
        distributing Xanax and OxyContin this year. The transactions, both
        during sting operations, involved more than 1,600 tablets, the
        indictment alleges.

        Goetz owns Pharmaceutical Returns, a reverse distributor of controlled
        substances that is authorized by the federal Drug Enforcement
        Administration (DEA) to collect the drugs and return them to the
        companies for credit or destroy them at approved incinerators.

        According to the indictment:

        In January, members of the Metro Gang Strike Task Force learned that
        Goetz was redirecting controlled substances to his drug customers just
        before or shortly after scheduled destructions. Officers set up a sting
        on Jan. 10 at Goetz's home involving 99 tablets of Xanax, an
        anti-anxiety drug. A second "controlled purchase" of 1,274 tablets of
        OxyContin, a painkiller, and 245 tablets of Xanax was conducted by the
        DEA and the task force on May 6 in a south Minneapolis apartment parking
        lot.

        Goetz was stopped as he was leaving the parking lot; officers seized a
        small amount of a controlled substance and a laptop computer.



        Jennifer Crittenden, M.S.W.
        Research Associate
        UMaine Center on Aging
        327 Camden Hall
        25 Texas Ave.
        Bangor, Maine 04401-4324
        Telephone: 207-262-7923
        Fax: 207-262-7921
        E-mail:Jennifer.Crittenden at umit.maine.edu <http://us.mc822.mail.yahoo.com/mc/compose?to=Jennifer.Crittenden@umit.maine.edu>

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