[Pharmwaste] Question on disposal of meds at end of school year

Volkman, Jennifer (MPCA) Jennifer.Volkman at state.mn.us
Thu Apr 29 12:28:49 EDT 2010


I suppose you've seen this:
http://www.deadiversion.usdoj.gov/pubs/brochures/stimulant/vaschool_meds.htm

We just did a presentation to schools and if the parents won't come and get the controlled substances, they are stuck with sewering, which DEA allows, but which is technically in conflict with our state HW rules.  All others can be shipped for HW incineration (expensive), or they can further sort and trash the non-haz pharms and store up the HW ones for shipment. I suppose they can't hold the students back until the parents come and get their pharms, but I'd be tempted to put that in my policy.  Maybe schools could require a $50 deposit for dispensing pharms and the parents get it back if they pick up the extra's.  If they don't, it can go toward disposal.

Most schools should be in the CESQG generation category, which, in some states, might allow for something like partnering with their D.A.R.E officer, sheriff, etc. to take them to a local law enforcement controlled substance locker.  Then law enforcement is responsible for proper management, but costs could be shared (if they properly manage their own CS).  An idea like this would not work in MN due to the way we regulates CESQ's. There would be RCRA regulatory issues with transport and possession/disposal, unless law enforcement would agree to be regulated as a CESQG consolidation site. Many schools in MN have been storing their left over CS, which was a surprise to me.  They want to do the best thing for the environment, but our current regulatory structure makes getting CS to an incinerator impossible.

I also like the "put them in a bucket of cement" encapsulation idea that came across the other day, it sure is better than sewering.

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Thompson.Virginia at epamail.epa.gov
Sent: Thursday, April 29, 2010 7:43 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Question on disposal of meds at end of school year


Does anyone have an example of a model policy for how schools can dispose of leftover student medications at the end of the school year?  It seems that many, if not most, schools flush whatever medications remain after the students leave for the summer, potentially causing a spike over a several-day period as all schools in an area flush at approximately the same time.

Any information about how schools do dispose of their leftover student medications or how they could dispose of them other than flushing would be appreciated.  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
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